item rio.
r—ITUX.A1411
.-ROM: OFFICE OF THE CITY MANAGER
BY: VANIAH DE ROJAS, ASSISTANT TO THE CITY MANAGER
SUBJECT> ADOPT THE UPDATED CITYWIDE LANGUAGE ACCESS PLAN AND CITY TITLE VI PROGRAM — TRANSIT
RECOMMENDATION
That the City Council approve and adopt the updated Citywide Language Access Plan and the City of Downey Title VI Program -Transit.
Title VI of the Civil Rights Act of 1964 prohibits discrimination based upon race, color or national origins. It requires that agencies receiving federal funding ensure that services are provided to all individuals without regard to race, religion or national origin. Downey receives direct federal funding from a variety of sources, including the Departments of Homeland Security, Housing and Urban Development, and Justice, as well as the Institute of Museum and Library Sciences, Federal Transit Administration (FTA), and the Federal Highway Administration. Moreover, several state and local agencies from which Downey receives funding are also recipients of federal funding, and are thereby required to ensure sub- recipients such as Downey have a plan in place to comply with Title VI.
TT'hile most federal agencies issue little guidance beyond allowing recipients to devise a plan that fits the organization's programs, community and budget, the FTA requires that all direct and primary recipients document their compliance with the Department of Transportation's Title VI regulations by submitting a Title VI Program -Transit to a FTA regional civil rights officer once every three years or as otherwise directed.
The City's Title VI Program — Transit is due for its tri-annual update this month, May 2022. City staff has worked with a consultant to review its current language access plan efforts related t#, transit and also conducted a survey of transit staff regarding their interactions with limited English proficiency communities.
Based on this review, the attached Title VI Program — Transit (Attachment B) was updated to comply with the three year update requirement and includes the required program content pe! the FTA.
Additionally, as part of the Title V1 Program — Transit update process, City staff also made minor modifications to the Citywide Language Access Plan. These minor changes include formatting, and removing of unnecessary dates and outdated information (Attachment A).
ADOPT THE UPDATED CITYWIDE LANGUAGE ACCESS PLAN AND CITY TITLE VI PROGRAM - TRANIST MAY24.2U22
PAGE
To ensure that all residents are given equitable access to City services and provided an opportunity take part in planning and decision -making (and as required by law as a recipient of federal funding), the City of Downey will ensure full compliance with Title VI of the Civil Rights Act of 1964 and other nondiscrimination statues as noted in the attached Language Access
FISCAL IMPACT
There is no fiscal impact to adopting the Citywide Language Access Plan and Title VI Program - Transit. However, there will be expenses associated with the provision of translation and interpreting services as required by federal law.
Quality mfLife, Safety and Infrastructure
Public Engagement
Attachment A: Citywide Language Access Plan
CITY-WIDE
TITLE VI PROGRAM:
LANGUAGE
ACCESS PLAN
ATTACHMENT A
I
I. Introduction ............ .... --- ... -- .... ... .. --- ... .... -- .... .. —,-- ..... —., 1 II. Title VI Language Access Plan (LAP) ..... ... - ... --- ... I A. Notifying Beneficiaries of Protection under Title VI ........................................................................ I B. Language Services/Resources Available for Staff to Provide Access for LEP Individuals ................ 2 1, Oral Interpretation
2. Written Translations
C. Criteria to Identify "Vital Documents ......................................... ........ ............................... 3 D. Policy on Use of Family and/or Friends for Oral Interpretation ...................................................... 4 E. Proactive Outreach to LEP Individuals ............................................................................................. 4 F. Title VI Complaint Procedures and Complaint Form ..................................................................... 4 G. Staff Training ... -- ... ................ ....... ......... ...... ...... — - - —, - - 7 Ill. Attachments
Attachment 1: Title VI Complaint Form ....-- ......... ....... ......—...--......- Attach ent 2: Title VI Complaint Log ..... ...... 11
Appendix 1: Department of Homeland Security ........ ...... ...... ....... ................ ........... ..... ----... 15 Appendix 2: Department of Justice. ..... --- ....... .......... -- ... ..... 18 Appendix 3: Institute of Museum and Library Services (IMLS), National Foundation on the Arts and the Humanities................. ............................................................ ............ ..................................... 21 Appendix 4: Housing and Urban Development ............................................................................... 23 Appendix 5: Federal Transit Administration » ...... -- ... ...... 2 5
Downey City- Wide Language Access Plan rev. May JQ22 2
1. INTRODUCTION
The City of Downey is proudly committed to continuously improving the quality of life for the Downey is a place of pride, history, civic involvement and community cohesion. The City is committed to ensuring that all citizens are provided services and opportunities to engage in City decision -making without regard to race, color, religion, gender, age, national origin, disability, marital status, sexual orientation, or military status. This commitment to inclusion and service is and as set forth in Title VI of the Civil Rights Act of 1964*, the City of Downey is reiterating its commitment to fair and equitable access to the City's services, specifically:
"0O person /n the United States shall, on the ground of race, color, or notkJnD/ origin, be excluded from participation /n, be denied the benefits of, orb8subjected to discrimination under any program or activity receiving Federalfinancial assistance. " (42 U.S. C. 2000d) Though this Language Access Plan addresses Title V1 requirements, Downey is nonetheless committed to regulatory requirements other nondiscrimination statutes that afford legal Discrimination Act of 1975 (age), and Section SO4 of the Rehabilitation Act of 1973/Americans with Disabilities Act of 1990 (disability).
the City of Downey will ensure full compliance with Title VI of the Civil Rights Act of 1964 and other nondiscrimination statues. Additionally, the City-wide Title VI complaint form includes an area to report any form of discrimination.
This Citywide Language Access Plan was updated in conformance with Title VI and other non- discrimination statues that afford legal protection (May 8, 2018, May 28, 2019, October 8, 2019, and May 2022).
111. TITLE VI CITYWIDE LANGUAGE ACCESS PLAN
A. Notifying Beneficiaries of Protection under Title V| In order to comply with 49 CFR, Section 2I.9(d), the City shall provide information to the public regarding the Cit/S obligations under the Title V| regulations and apprise members of the public Of the protections against discrimination afforded to them by Title V|.
The City of Downey will inform members of the public of their Title VI protection in a variety of ways, including:
w (]nthe [it/svvebsite at (The VVebsite also includes a link totranslate the xvebpageinto Spanish)
• On City agendas, which are printed in both Spanish and English; • Posting of notices inside all Dia|'A'Ride and Fixed -Route vehicles; w Posting of notices in the public area of City Hall, the Transit Center, the Barbara J. Riley Community and Senior Center, the McCaughan Gym, the Downey City Library, and the Downey Police Department.
The City has developed several resources which will be available for staff to provide free and appropriate translations or interpretation. These resources include:
—1. Oral InterprPtatinn - — -
The City has various resources to provide oral interpretation. These resources cover a range of interpretive needs, from technical language to simple communications such as requests for forms, completion of simple applications, and providing directions or answering general questions.
These resources currently include:
• Spanish-speaking staff members who have been tested and receive bi-lingual pay; • Contracted telephonic and on -demand video interpretation e.g. Language Line for Spanish or other languages;
• On -call consultant resources for in -person and written translation • Connections with community organizations serving the specific LEP population; • Staff members who speak a language in addition to English and have not beentested*; • Bi-lingual volunteers, including volunteers from Fire and Police Explorers, Friends of the Library, and Columbia Memorial Space Center volunteers and Parks and Recreation volunteers*; and
• Use of Google Translate via computer, tablet or cell phone* these resources will be used primarily for simple form completion, outreach events, and basic service inquiries such as office hours or directions 0 91 1 0 . I .
On -Demand Oral Interpretation. Generally, interpretation will be available "on demand" for standard inquiries about City services, codes and permits, police activities and enforcement, and administrative procedures, including assistance in completing forms which are not available in the LEP individual's language.
Advance Notice Oral Interpretation. On occasion, prior notice of the need for oral interpretation will be required. Generally, this will occur when City procedures or the technical nature of the interpretation requires special arrangements, including:
• Oral interpretation of public comment at City Council, Committee or other government meetings will require 48 hours advance notice (as will be stated on the public notices).
• Oral interpretation of services with technical language (e.g. building and safety) may require advance notice to identify interpreters with the relevant knowledge.
In all cases where advance notice is required, the City will make every effort to minimize the delay and ensure the needs of the LEP individuals are met.
Downey City -Wide Language Access Plan rev. May 3O22 3
The City will have available upon request translated versions of forms/service information which are most commonly used or are considered "vital" under City policy (Section 11, Part C, Criteria to Identify "'Vital Documents").
The City will begin translating forms and service brochures as requested by Korean LEP individuals. For vital forms, the city will provide initial oral interpretation of the form or publication and will follow with written translations if requested by the LEP individual.
Untranslated vital documents will, whenever possible, carry a statement in Korean informing LEP Korean speakers that translation into Korean is available. c. Other languages
The City will rely on telephonic or qualified local interpretation of forms and service information for lan,qua.ges other than Korean or Sni:111111,16'ih6. F%r "vil documents. the citv will The City has determined that the following factors will be used to guide staff in their classification following factors when classifying documents:
1. Forms that are required to be completed before the LEP individual may access a Qjy servic for example:
• Library card applications
• Application or registration forms
• Intake forms
CommonIv used forms or public outreach matorials that seldom change and are central for important services or that commonly result in fines or may, have,other financial impact, for * Yard Sale Permits
]. for example:
• Semiceou dback forms
• Notices Ofpublic briefings orfocus groups
4. Service announcements and materials that serve as the principal outreach mechanism.
Since "lack ofawareness that @ particular program, right, orservice exists may effectively deny LEP persons meaningful access," staff will regularly @G9e5S the needs of the populations frequently encountered or affected by the program or activity to determine whether certain outreach materials should be translated. Note that budget considerations and/or outreach methods may require that the format of the translated text may be different from the English
Downey City- Wide Language Access Pion rev. May 2022 4
IM
111�11 1111111111 111 11� IIIIIIIIN
Surveys of staff and managers in the City of Downey have demonstrated that it is most common for LEP individuals to bring an English -proficient friend • • member when accessing City services.
The City respects the LEP individual's right to select their own interpreters. However, the City also recgolizes its"resporisibility to ensure"t'hat LE-Plilndividuals, m-alklel-a-ril informed choice.1"Thlerefore, a notice in English, Spanish, and • will be posted at public • and public information boards informing LEP individuals that certified interpretation services are available at no cost to the LEP individual.
Further, in some situations staff may determine that a friend/family interpreter may not be appropriate, including situations where:
* the language is too technical and/or requires specialized understanding; * the interpreter may have a conflict of interest (generally legal matters); or, * the subject matter is inappropriate or too advanced for use of a minor child (e.g. code enforcement, domestic violence).
In these instances, staff will be instructed that, whenever possible, they should call a certified staff — interpreter or a telephonic — interpreter to help ensure the LEP individual understands their right to a free translator.
E. Proactive Outreach to LEP Individuals
The City of Downey is committed to facilitating and encouraging participation by all Downey residents in civic planning and services. Downey has used — and will continue to use — a number of avenues to reach the greatest number of residents. These activities include, but are not limited to:
* working directly with the network of community organizations and social services agencies that serve Downey to reach LEP populations and to track the needs of the communities they serve;
0 ensuring public workshops, focus groups, and community meetings are held at a variety of times and locations and that interpreters for Spanish and Korean are available (by request) either in person • by phone;
,o disseminating flyers or notices through the schools; * • distributing • materials, including the use • • media.
The City • Downey takes allegations • discrimination • any kind very seriously. Three specific 'g•." of discrimination fall •:, Federal Title VI regulations: discrimination • the •.... of race, color or national origin. As a recipient of Federal funding, the City is required to develop The City has developed the following Title VI complaint procedures. Both the complaint procedures • the complaint form will be posted in English, Spanish and • • the City's website. They will also be available on the City's shared network drive for any City staff member to print as requested. This procedure is the same for other nondiscrimination statues complaints (except for ADA complaints as the City has developed a separate ADA Complaint and Grievance Procedure.)
Downey City -Wide Language Access Plan rev. May JD2J 5
If a patron believes he/she has received discriminatory treatment on the basis of race, color, religion, gender, age, national origin, disability (handled by a separate process), marital status, sexual orientation, or military status, including limited English proficiency, by a City of Downey staff member or a staff member of a contract service provider (e.g. the Transit contractor), the patron will have the right to file a complaint with the City. The complaint must be filed within 180 calendar days of the alleged incident. Title VI complain! procedures will be available in English, Spanish and Korean.
Once filed, the City Manager's Office, or its designee, will investigate the complaint. The investigation may include diScuSsimn(s)ofthe complaint with all affected parties, including witnesses, to determine relevant facts in the matter.
The City will only investigate complete complaints. If the City requires more information to initiate the investigation, the City may contact the complainant to request more information. The complainant has 10 business days from the date of the City's request to provide requested information to the investigator or request more time to gather the information. If the complainant does not respond to the request within 10 business days, by the City's investigator, but the 10 business days' time period remains in place from the date of extension. The City may also close the complaint if the complainant no longer wishes to pursue their complaint.
The City will commence an investigation within lO business days of receipt of the complaint.
(c) Resolution of Case
After the investigation ofthe complaint iscompleted, the City will issue one oftwo letters to the complainant: a closure letter or a Letter of Finding (LOF). A closure letter summarizes the allegations, states that there was no finding 0fa Title V| violation, and that the case will be closed. An LOF summarizes the allegations and the factual findings of the investigation and provides that appropriate responsive action will betaken, including discipline or additional training of the staff member, contract staff, etc.
The Letter DfFinding will also notify the complainant ofhis/her right tQsubmit arequest for reconsideration regarding the results of the investigation. If the complainant disagrees with the Cit«'s findings the complainant may request reconsideration by submitting a written request to the City Manager's Office within 10 business days of receipt of the City's response. The complainant shall provide a detailed description of the request for consideration. The City will notify the complainant of its decision either to accept or reject the request for reconsideration within IO business days. If the City agrees to reconsider the matter, the complaint shall be returned to the investigator for re-evaluation in accordance with the "Investigation of Complaint" procedures described above. (e) Appeal Process
lg� 111111 111
?Me reqTeST TO - ITIon is 0-171-ilea, ne cortipiainanr-rn-&T-gp'p-e-a-rff ' 177TT"61 submitting a written request to the City Manager for final determination.
Complainant may, at any time, submit the complaint directly to the relevant Federal U.S. Department of Transportation, Federal Transit Administration- Office of Civil Rights, Atte TCR, 1200 NgA Jersey
Avenue, SE, W I ashingon, DC 20590. (In accordance with Chapter 9, Complaints, of FTA Circular 4702.113, such a complaint must be filed within 180 calendar days of the date of the alleged discrimination.
a Administration, Office of Civil
Rights, 1200 New Jersey Avenue, SE, 8th Floor E81-105, Washington, DC 20590. (202)366-0693, [email protected]
0 U.S. Department of Housit2jg-Ap One Sansome Street, Suite 1200, San Francisco, CA 94104, (415) 489-6400
U.S. D950 Pennsylvania Avenue, NW, Washington, DC 20530- 0001. (202) 514-2000
Office for Civil Rights and Civil Liberties, Review
and Compliance, 245 Murray Lane, SW., Building 410, Mail Stop #0190, Washington, DC 20528. (866) 644-8360, Toll Free TTY: (866)644-8361, Fax: (202) 401-4708, [email protected].
The City has developed a Title VI Complaint Form (Attachment #1) to document all complaints received by City and/or contractor staff. This form is available in English, Spanish and Korean on the City's website and from any staff member from the City's shared network folder. The form will also be available via email or US mailed for free upon request.
The City will maintain a list (Attachment #2) of all Title VI and of other nondiscrimination the basis of race, color, religion, gender, age, national origin, disability, marital status, sexual orientation, or military status in City activities and programs. The list will include shall include:
• The date that the investigation, lawsuit, or complaint was filed, • A summary of the allegations(s),
• The status of the investigation, lawsuit, or complaint, and • Actions taken by the City in response, or final findings related to the investigation, lawsuit, or complaint.
Resources' office on a periodic basis. As of May 24, 2022, the City of Downey had two Title VI - complaints, investigations, or lawsuits.
Downey City -Wide Language Access Plan rev. May 2022 7
G. Staff Training
The City will take steps to ensure that all staff and Department Heads — not just those from "froni desk" programs — are aware not only of the importance of serving LEP individuals, but also the various methods available to serve the LEP population.
At least annually, Title VI and the City's Title VI Language Access Plan will be an agenda item at a weekly Department Head meeting. At that time, Department Heads will receive training on the requirements of the City's Title VI plan. Training will include:
* types of language services available;
0 how staff can obtain those services;
• how to respond to LEP callers and visitors;
• how to handle written communications from LEP persons; and, • how to determine which interpretation and/or translation avenue is more appropriate based on complexity and importance of the subject being translated or because a potential conflict of interest exists.
Title VI guidelines and information will be given to all new hires — whether full time or part time — as part of their regular new hire orientation. This information will include information on Title VI requirements as well as instructions on what to if if they encounter an LEP individual.
Similarly, managers are required to ensure that volunteers are trained in the requirements of Title VI and how to respond to LEP callers and visitors.
ATTACHMENT #1
--- - ------
= TITLE VI COMPLAINT FORM =
[a, City -,',Downey
As set forth in Title VI of the Civil Rights Act of 1964:
"No person in the United States shall, on the ground of race, color, or notional origin, be excludedfrom participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federolfinancial assistance. " (42 U.S. C. 2000d) If you believe you have been the target of discrimination on the basis of race, color, national origin, religion, gender, age, disability (handled through a separate the a complaint and grievance procedure), marital status, sexual orientation, or military status, please complete this form in as much detail as possible. This completed form must be submitted within 180 days of the incident. if you need help completing this form for any reason, please contact the City Manager's Office at (562) 299-6619.
IP
Section 1:
Name -
Address:
Telephone (Home): Telephone (Cell):
Email Address:
Section III:
Are you filing this complaint on your own behalf? Yes No If you answered "Yes," go to Section III
If you answered "No":
Please supply the name and relation -ship of
the person for whom you are filing this form.
Explain why you have filed for
a third party:
Have you obtained the permission of the aggrieved party? E] Yes F] No Section IIII:
I believe the discrimination experienced was based on (check all that apply). r-1
E] Race 1:1 Color 11 National Origin L_j Other*
Date of Alleged Discrimination (Month, Day, Year):
(continued on back)
Downey City -Wide Language Access Plan rev. May 2022 10 Explain as clearly and completely as possible what happened and why you believe you (or another) were discriminated against. Describe all persons who were involved. Include the name and contact i information of the person(s) who discriminated against you (if known) as well as names and contact information of any witnesses, If more space is needed, please attach additional sheets.
Section IV:
Have you previously filed a Title VI complaint with this agency? OYes NO Section V:
Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or State court? 0 Yes [j No
If yes, check all that apply and list the agency's name:
Federal Agency State Agency
ElFederal Court State Court
11 Local Agency El Other
Please provide information for the contact person at the agency/court(s) where the complaint was filed, (Please attach additional sheets if more than one agency/court.) Name:
Title:
Agency.
Address:
Telephone:
Please attach any written materials or other information that you think is relevant to your complaint.
Signature and date are required,
I
NIM
Please submit this for in person at the address below, or mail this form to:
City Manager's Office
11111 Brookshire Ave,
Downey, CA 90241
(562) 904-7292
ATTACHMENT
TRACKING OF TITLE VI
INVESTIGATIONS, COMPLAINTS
AND LAWSUITS=
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The City-wide Language Access Plan applies equally to all City departments and programs. In addition, some federal funding sources have specific rules or address specific programs. The following appendices are intended to address agency -specific requirements or federal agency guidance(s) that impact selected programs or departments.
APPENDIX #1
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The US Department of Homeland Security provides additional oversite of civic Police and Fire departments. For police, the DHS guidance mirrors that of the US DOJ. Therefore discussion of special Title VI policies and procedures for the Downey Police Department are addressed in Appendix 3 (US -Department of Justive section).
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A. Fire Dispatch
Through a contract provided by the California Office of Emergency Services, the dispatchers the Joint Communication Center which dispatches for Downey Fire have access to the City telephone and on -demand video interpretation services for any LEP calls. Dispatchers a trained to connect with and work through the telephonic service. I B. Emergency Medical Services
2 in emergency situations. Through a City contract, staff also have access the same telephone a on -demand video interpretation service used in the dispatch center.
C. Community Outreach and Involvement
Downey Fire Department is committed to ensuring LEP communities have access to t information needed to practice fire safety, including: I
1. Outreach Materials
Whenever possible, Downey Fire will provide public outreach and education materials in both Spanish and English. For general education materials (e.g. smoke alarm maintenance), the department might use existing translated materials from other Fire organizations such as LA County Fire, the National Fire Prevention Association, etc.
2. Explorer Recruitment
in packages sent to community outreach partners. (Because English proficiency is required for the program, materials will be sent in English only.)
3. Community Emergency Response Team (CERT)
To encourage participation by bilingual individuals, CERT outreach materials will be included in packages sent to community outreach partners. In addition, Downey will work with Area E Regional CERT to find ways to recruit and train bilingual CERT trainees with an emphasis on Spanish -speakers.
D. DHS-related Complaints
In addition to the city-wide Title VI complaint procedures outlined in section 11 F, compla alleging that the City has failed to provide meaningful access to programs and services for I
III• illis I,
Department of Homeland Security,
Office for Civil Rights and Civil Liberties, Review and Compliance 245 Murray Lane, SW., Building 410
Mail Stop #0190
Washington, DC 20528.
Local: 202-401-1474, Toll Free: 1-866-644-8360,
Local TTY: 202-401-0470, Toll Free TTY: 1-866-644-8361, Fax: 202-401-4708.
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APPENDIX #2
IT M= - =
The Downey Police Department is committed to protecting the lives, property and rights of al' community members — regardless of language abilities.
A. Law Enforcement Continuum
Downey Police Department has policies and procedures to serve LEP individuals at every step of the Law Enforcement Continuum.
1. Receiving and Responding to Requests for Assistance
• Downey Police Dispatch (911 and non -emergency calls) have access to telephonic interpretation at all times. In addition, Spanish language experience is "strongly preferred" in the hiring of dispatchers.
• For urgent calls from LEP speakers, bi-lingual officers (if on duty) are cleared to respond immediately.
• For non -urgent LEP calls or calls where bi-lingual officers are not on duty, all officers dial Police Dispatch and the dispatcher can give them the client ID number and transfer the officer to the interpreter service and follow the prompts for the language requested.
• Enforcement Stops Short of Arrest and Field Investigations • For enforcement stops, Downey PD applies the same policies as described above for responding officers.
2. Intake/Detention
Downey operates only a temporary holding facility. The same interpretation resources will be used to provide appropriate explanations and elicit necessary information.
Downey Police Department currently oNers the opportunity for officers and staff to take bilingual certification tests in Spanish and several other languages. For steps I and 2 on the Law Enforcement Continuum, the preferred procedure is to have bilingual officers or PD staff (depending on situation) respond to the call.
For languages for which no staff/officer are certified, officers are trained to judge whether a family/friend may act as oral interpreter. The officers take into account several factors, including possible conflicts of interest, the subject matter (particularly when a minor is functioning as inter-creter4, and the severitirA of the issue. If there is anwtuestion of the aMlroyriatenes of usin informal interpreters, officers are instructed to call the professional telephonic interpretation service.
11150-MMUTI-TIM in
The Downey Police Department recognizes the importance of outreach to the LEP community.
It is a yrioof the PD to not onlo recruit bilin
outreach and coordination with LEP populations.
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To encourage participation by bilingual individuals, Explorer outreach materials will be included in packages sent to community outreach partners. (Because English proficiency is required for the program, materials will be sent in English only.)
2. Neighborhood Watch
The departments current Neighbo-rhDod Watch Coordinator is bi-lingual -in -Spanish and English. The Neighborhood Watch brochure is in English and in Spanish and the department is currently working on translating the flyer and fundamentals out to Spanish. If questions do arise in a language other than English and there are no on -duty personnel available to provide document translation, and telephonic and on -video interpretation service is used.
APPENDIX
INSTITUTE OF MUSEUM
AN D Li BRARY SERVICES V M LS)
A. Vital Documents
As indicated in the City-wide Language Access Plan, documents that provide access to Library services will be translated into Spanish (or Korean upon request). Specifically:
* Library Card Application
* Library Brochure/Description of Services, including:
• Children's program fliers
• Adult literacy program
• Online Library catalog
• Computer lab and WiFi information
• Listing of Computer classes
B. Collections/Holdings
The Downey Library has existing Spanish and Korean language collections. Signs in Korear and Spanish provide clear visual indication that these holdings are available.
C. Volunteer Recruitment
To encourage participation by bilingual individuals, information on Library volunte opportunities will be included in materials circulated to community partners. I A. Volunteer Recruitment
To encourage participation by bilingual individuals, information on docents and museu volunteer opportunities will be included in materials circulated to community partners. I B. Exhibit Translation
The City will explore ways to • with community partners to translate the exhibil information for permanent exhibits into Spanish. One exhibit signage has Spanish translation, with additional exhibits in progress • being translated.
im 0
As required by (24 CFR 91, Subpart B, "Citizen Participation and Consultation"), the following steps will be taken to ensure LEP individuals are able to fully participate in planning.
1. Comm un ity-ITI eeti ngs
In order to encourage the greatest possible participation of all elements of the community — including LEP individuals — the Community Development Department offers community meetings at various times and locations. Announcements of these meetings will be posted in English • • (with the key information translated into Korea, • meeting title, date and location and • to request a full • Notices will carry a statement that telephonic and on -demand video interpretation is available upon request and with I L L advance notice.
2. Draft and •
Plans
Any drafts and final plans which are made available to the public will be translated into •. and posted • the City website and circulated to community partners and any resident who • to receive the • and final plan.
The Community Development Department will pursue a range of outreach avenues to reach those LEP individuals who are least likely to apply. These methods include:
• helping with interpretation and/or translations and community access (as requested) to nonprofits who build and manage low-income housing in Downey; • postings • the City website and • media;
• posting bilingual outreach materials in City buildings; and, • circulating outreach materials about services, programs and community meetings • the City's community network. The • network comprises those • organizations that are most likely to provide services for low income and/or LA?� individuals (e.g. churches, food banks, school district, adult school, etc.)
Downey City -Wide Language Access Plan rev. May 2022 25 APPENDIX #5
Note:
The FTA has specific requirements for a Title VI plan for the City's Transit Services. An updated Title V1 Plan must be submitted every three years and must include a report on outreach efforts, city demographics, Transit system standards, and other Transit -specific requirements. The following pages represent the full submission for FTA and will include information already contained in the policies and procedures above.
22• i'
This document sets forth policies and procedures to effectively monitor and ensure that Downey Transit Services are in compliance with Title VI of the Civil Rights Act of 1964 as required by the US Federal Transit Administration.
ATTACHMENT B
I. Introduction .... ............ ......... ..... ____ ... - . . . I A. Requirement to Notify Beneficiaries of Protection under Title VI ................................1 B. Requirement to Develop Title VI Complaint Procedures and Complaint For ............2 C. Requirement to Record and Report Transit -Related Title VI Investigations, Complaints, and Lawsuits. ......... ............ _2
D . Promoting Inclusive Public Participation and Language Assistance ................ .... 3 E . Providing Meaningful Access to LEP Persons............. ............... ...... — 3 F . Minority Representation on Plan n i ng/Advisory Board ...................... __3 G . Determination of Site or Location of Facilities ........... ............................... ........ __._4 H. Fixed -Route Provider: System -Wide Standards and Policies ....................................... 4 I. Obligation to Provide Additional Information to FTA upon Request ......... ....... _ 4 Ill. Attachments
Attachment 1: Notice of Civil Rights ................ ...... .......... ...... ___ ........... 5 Attachment 2: City-wide Title VI LAP Excerpt: Complaint Process ....................................1 Attachment 3: Title VI Complaint For........................................................................... _ 14 Attachment 4: List of Transit Related Title VI Investigations, Complaints, and Lawsuits.. 17 Attachment 5: Public Participation Plan ........................................................................2 Attachment 6: Title VI Language Assistance Plan .......... ....... __ ....................................... 24 Attachment 7: System -Wide Standards and Policies.,..... .. .......................................... 30
1 City of Downey Transit Services Title VI Program e May 2022 The City of Downey is ap|Gce of pride, history, involvement, and community. The City is committed to ensuring that all citizens are provided services and opportunities to engage in City decision -making without regard to race, color, religion, gender, gender expression, age, national origin, disability, marital status, sexual orientation, Ormilitary status. This commitment to inclusion and service is reflected in the Title V| Program ofDovvnev'sTransit Services. As required by the Federal Transit Administration (FTA), Federal Highway Administration (FHVVA), and as set forth in Title V| of the Civil Rights Act of 1964, the City of Downey is reiterating its commitment to fair and equitable access to the City's transit services, specifically:
"No person /nthe United States shall, Dnthe ground ofrace, color, ornational origin, be excludedfrom participation in, bedenied the benefits of, mrbesubjected to discrimination under any program or activity receiving Federal financial assistance." /42 U.S.0 2000oU
Toensure that all residents are given equitable access to Transit Services and that all citizens are provided anopportunity take part inTransit planning and decision -making (and as recipient of federal funding), the City of Downey Transit Services will ensure full compliance with Title V| of the Civil Rights Act ofI964.
The Title VI Program -Transit was adopted by the Downey City Council in conformance with FTA C47O3.18(October 1,2Ol2,April 26,3OIG,May 38, 2Dl9October 2i2DI9and May 24`JOZ3\.
On November 18, 2020 this Policy was updated to incorporate an updated FTA mailing address regarding complaints and web link to the City's Title V1 webpage. No other changes were made. |norder tocomply with 49 CFR,Section 21.9(d),the City shall provide information tothe public regarding the Cih/s obligations under DOT'S Title V|regulations and apprise members mfthe public ofthe protections against discrimination afforded tothem byTitle VI.
The City of Downey will inform members of the public of their Title VI protection in a variety of way, including:
• On the Ckv'svvebsite athttp .dovvneyca.mre/tit|eV| (The VVebsite also includes alink totranslate the vvebpageinto 5penish);
• OnCity agendas, which are printed inboth Spanish and English; • Posting ofnotices inside all Dial -A -Ride and Fixed -Route vehicles; and, * Posting ofnotices inthe public area ofthe Transit Center.
Copies ofnotices can befound inAttachment #I.
moHMEEMM-13mcEmolm
The City of Downey takes allegations of discrimination of any kind very seriously. Three specific categories of discrimination fall under Federal Title V1 regulations: discrimination on the basis of race, color and national origin. As a recipient of Federal funding, the City is required to develop procedures for investigating and tracking Title VI complaints filed against the City's Transit Services and to make these procedures for filing a complaint available to the general public.
2. Ensur�i Ens access to Complaint Form and Procedures
The City has developed a Title V1 Complaint Form to document all complaints received by City and/or transit contractor staff (Attachment #3). This form is available in English, Spanish and Korean on the City's website and at the City of Downey Transit Depot located at 8150 Nance Ave., Downey, CA 90241. The form is also available via email or can be mailed upon request.
C. Requirement to Record and Report Transit -Related Title VI Investigations, Complaints, and Lawsuits.
The City is required to prepare and maintain a list of investigations, complaints, or lawsuits th pertain to allegations of discrimination on the basis of race, color, and/or national origin in transit -related activities and programs. The City will maintain a list of Transit Services Title V1 investigations, complaints, and lawsuits, including a comprehensive summary and description of actions taken by the City, as required by Title VI regulations (see Attachment #4). The list shall include:
The date that the investigation, lawsuit, or complaint was filed, A summary of the allegations(s),
The status of the investigation, lawsuit, or complaint, and Actions taken by the City in response, or final findings related to the investigation, lawsuit, or complaint. I
The list will be maintained by the City Manager's Office and an updated copy provided to thd Human Resources' office on a periodic basis.
3 City of Downey Transit Services Title VI Program e May 2022 Transit Services' Public Participation Plan is designed to encourage participation by all Downey residents in transit planning and services. Downey Transit Services has used — and will continue to use — a number of avenues to reach the greatest number of residents. These activities include, but are not limited to widely disseminating bilingual brochures as well as biannual mailings to LEP Outreach List to ensure access by their LEP clients and attendees. The full Public (Spanish/English) to ensure that all outreach efforts include LEP Spanish speakers. In addition, Downey has implemented a city-wide Title VI LAP Program that includes contracting with telephonic translators, creating "Point to Your Language" cards for all staff who interact with the public, and posting notices at key sites of the number to call for translation assistance.
E. Language Assistance Plan and Requirement to Provide Meaningful Access to Limitel], English Proficiency (LEP) Persons.
The Language Assistance Plan includes two components; a Title VI Limited English Proficiency Analysis (LEP Analysis), and a Language Assistance Plan. The LEP Analysis is a four factor analysis, which considers:
0 The number of LEP persons in the service area,
* The frequency that LEP persons come in contact with transit services, i The nature and importance of programs, activities or service to the LEP population, and * The resources available to the City and overall costs to provide LEP assistance.
The Language Assistance Plan explains the findings of the Four Factor Analysis and describes Title V1 and its implementing regulations require that FTA recipients take responsible steps to ensure meaningful access to benefits, services, information, and other important portions of their programs and activities for individuals who have Limited English Proficiency. In addition to the steps outlined herein, the City collaborates with the Los Angeles County Metropolitan Transportation Authority (Metro) and other neighborhood stakeholders to ensure LEP persons have access to necessary information.
transportation related policy decisions. Therefore, this requirement does not apply to the City of Downey. The city of Downey will follow all Title V1 Requirements if a transit advisory council or committee should be formed at an undetermined future date. related facilities such as storage facilities, maintenance facilities, or operations centers.
Therefore, this requirement does not apply.
1111TOW-Ur M_
policies for their fixed -route service.
The City has developed service standards and policies for its fixed -route system consistent with Title V1 requirements. The standards include (a) vehicle load; (b) vehicle headway; (c) on -time performance; and (d) service availability. The policies include (a) the policy for the distribution of transit amenities, and (b) vehicle assignment policies (see Attachment #6).
IT.TV1.374M "Mill 11;1111�1 11�111 1�1111111111111!1 I
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The City of Downey's City Manager's Office is available to provide additional information, as needed, and to respond to any verbal or written requests for information in order for FTA to investigate complaints of discrimination or to resolve concerns about possible noncompliance with DOT's Title VI regulations.
5 City of Downey Transit Services Title VI Program • May 2022 NO"TICE U'-*-F CIVIL RIG"11 1j=
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6 City of Downey Transit Services Title VI Program @ May 2022 Notice of CiMLI Wights ® Website Text
http://www.downeyca.org/TitieVi
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Public Notice of Rights
under Title V1 of the Civil Rights Act
In keeping with the City's tradition of community and involvement, Downey Transit Services is committed to ensuring that no person is excluded from participation in, or denied the benefits of its service on the basis of race, color or national origin as provided under Title VI of the Civil Rights Act. In addition, Downey prohibits discrimination based on sex, age, disability., religion, sexual orientation, gender identity, and other protected classes enumerated in federal and state laws.
If you have any questions about the Title VI Civil Rights Act or would like additional information on Downey's obligation regarding non-discrimination, please visit the Title VI Nondiscrimination & Language Access Plan page on the City website or call (562) 299-6619, If you believe you have been discriminated against, you have 180 days from the date of the alleged discrimination to file a signed, written complaint. The complaint should include the following information:
• Your name, address, and how to contact you (i.e., telephone number, email address) • How, when, where, and why you believe you were discriminated against. include the location, names, and contact information of any witnesses.
A full description of the Complaint Process and complaint form is available on the Transit section of the City's website or at the Transit.
The complaint should be filed in writing with:
Downey City Manager's Office
11111 Brookshire Ave., Downey, 3rd floor
(562) 299-6619
a
I file Civil Rights Act 1�1 +6 =A
You may also e a v g 5 C e complaintwith e at:
U,S. Department of Transportation
Federal Transit Administration
Office of Civil Rights
Attention: Complaint Team
East Building, 5th Floor — TCR,
1200 New Jersey Avenue, SE,
Washington, DC 20590
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Downey Transit Services operates its programs and services without regard to race, color or national origin in accordance with Title VI of the Civil Rights Act. (Downey also prohibits discrimination based on sex., age, disability, religion, sexual orientation, gender identity, and other protected classes enumerated in federal and state laws.) Any person who believes he/she has been a victim of any unlawful discriminatory practice sander Title VI may file a complaint with Downey City Manager's Office.
If you have any questions or would like additional information on Downey°'s obligation regarding non-discrimination or how to file a complaint, please visit the Title VI Nondiscrimination Language Access Plan page on the City"s website or call (562) 299- 619.
You may also file a complaint directly with the Federal TransitAdministration:
Federal Transit Administration, Office of Civil Rights, Attention: Complaint Team, East Building,th Floor — TCR, 1200 NewJersey Avenue, SE, Washington, DC 20590
If information is needed in another language, please contact (562) 299-6619 s
cl
Public Notice of Rights Aviso Pu'blico de Derechos
Downey Transit Services operates its programs and services without regard to race, color or national origin in accordance with Title VI of the Civil Rights Act. Downey also prohibits discrimination based on sex, age, disability, religion, sexual orientation, gender identity, and other protected classes enumerated in federal and state laws. Any person who
believes he/she has been a victim of any unlawful
discriminatory practice under Title VI may file a complaint with the Downey City Manager's Office,
If you have any questions or would like addition a I information on Downey's obligation regarding non-discrimination or how to file a complaint, please visit the Title VI Nondiscrimination & Language Access Plan page on the City's website or call conformidad con el Tftulo VI de la Ley de Derechos Civiles. relativa a la obligacicin de Downey en materia de no
If infor ation is needed in another language, please call (562) 2.99-6619 OWL
CITY-WIDE TITLE V1 LAP EXCERP
11 City of Downey Transit Services Title V1 Program 9 May 2022 The City of Downey takes allegations of discrimination of any kind very seriously. Three specific categories of discrimination fall under Federal Title y| regulations: discrimination on the basis of race, color or national origin. As a recipient of Federal funding, the City is required to develop procedures for investigating and tracking Title V| complaints filed against the City and to make these procedures for filing a complaint available tothe general public.
The City has developed the following Title V| complaint procedures. Both the complaint procedures and the complaint form will be posted in English, Spanish and Korean on the Citus website. They will also be available on the City's shared network drive for any City staff member to print as requested. This procedure is the same for other nondiscrimination statues complaints (except for ADA complaints as the City has developed a separate ADA Complaint and Grievance Procedure.)
1. City of Downey Title V1 Com laint Procedures
(a) Complaint Submission
if a patron believes he/she has received discriminatory treatment on the basis of race, color, religion, gender, age, national origin, disability (handled byaseparate process), marital status, sexual orientation, or military Status, including limited English proficiency, by a City of Downey staff member or a staff member of a contract service provider (e.g. the Transit contractor), the patron will have the right to file a complaint with the City. The complaint must be filed within 180 calendar days of the alleged incident. Title VI complaint procedures will be available in English, Spanish and Korean. /b\ Complaint investigation Process
2 Per the FHVVAGuidance Memorandum, Processing ofTitle VY Complaints,dated June 23, 2018, all Title V| complaints received by a sub -recipient (the City of Downey) will be forwarded to Ca|trmns (email to: Tit|£.V|@dot.Ca.gOv) to be submitted to FH\0A Division Office within one business day qfreceipt.
Similarly, if a complaint is received by an FTA sub -recipient, those are to be forwarded to the FTA for investigation or review (mail to: Federal Transit Administration- Office of Civil Rights, Attention: Complaint Team, East Building, 5th Floor —T[R, 1200 New Jersey Avenue, SE, Washington, OC2O59O).
The FHVVA/FTA will then forward that complaint to the U.S. Department of Transportation Headquarters Office of Civil Rights (HCR) within one business day of receipt. If HCR determines a Title V| complaint against a sub -recipient can be investigated by a Ca|trans, HCR may delegate the task of investigating the complaint to Caltrans. If Caltrans' Office of Business & Economic Opportunity (OBEO) is delegated the responsibility ofperforming an investigation, [)BE[) has9O days to investigate the complaint. If additional time is needed, C)BE(]will call the Complainant and inform
12 City of Downey Transit Services Title V1 Program *flay 2022 R
If more information is needed to resolve the case, the OBEO investigator may contact the Complainant. The Complainant has ten business days from the date of the letter t# send the requested information to the investigator assigned to the case.
If the investigator is not contacted by the Complainant or does not receive the irtg'
the disposition of the complaint. Disposition of Title VI complaint will be undertaken by HCR, through either (1) hjNrmal resolution or (2) issuance of a Letter of Finding of to all parties via the Division Office.
FTA — Filing a Local Complaint
FTA recommends, but does not require, that individuals first file a complaint directly with their transit provider to give it an opportunity to resolve the situation. FTA grantees are required under the ADA, Title VI, and EEO to have local complaint procedures.
Complaints Filed Against California Department of Transportation (Caltrans) Written complaints filed with Caltrans in which Caltrans is named as the Respondent will be forwarded to Federal Highway Administration (FHWA) Division Office, or Federal Transit Agency (FTA), depending on who is the oversight agency, for investigation. The FHWA/FTA will then forward that complaint to the Headquarters Office of Civil Rights All complaints filed under Title VI against State DOT's are investigated by HCR. (a) Submission of Complaint Directly to Caltrans and to the Federal Department Complainant may, at any time, submit the complaint directly to the relevant Federal Department for investigation, including:
* California Department of Transportation, Office of Business & Economic Opportunity, 1823 14th Street, Sacramento, California 95811. (916) 324-0449, TTY 711, [email protected]
* U.S, Department of Transourtatign, Federal Hiphwav Administration, Office of Civil Rights, 1200 New Jersey Avenue, SE, 8th Floor E81-105, Washington, DC 2050.9 (202)366-0693, [email protected]
0 Title Vi And Other Discrimination Complaint Form -
https:Hforms. dot.ca.gov/v2Forms/serviet/Form Rend erer?f rm id =OBEOOO 02 FORMULARIO DE QUEJAS DE DISCRIMINACibN DEL T(TULO VI Y OTRAS - http://cefs2.dot.ca.gov/v2Forms/serviet/FormRenderer?frmid=OBEOOOO 2ES
FHWA F.A.Q for Complaints Alleging Violations for Title VI - https://www.fhwa.dot.gov/civilrights/programs/docs/FHWA Title VI%2n —Complaint_QA.pdf
13 City of Downey Transit Services Title VI Program 9 May 2022 • U.S. De :artment of Ttanspp-gaton, Federal Transit Administration- Office of Ci Rights, Attention: Complaint Team, East Building, 5th Floor — TCR, 1200 New Jers Avenue, SE, Washington, DC 20590, such a complaint must be filed within 1 calendar days of the date of the alleged discrimination. • U.S. Department of Housing and Urban DevelgpD20t One Sansome Street, Sui • U.S. Department of Justice 950 Pennsylvania Avenue, NW, Washington, DC 2053 • US DepartMent of Homeland Security, Office for Civil Rights and Civil Libertie Review and Compliance, 245 Murray Lane, SW., Building 410, Mail St
2. Ensuring Easv Access to Complaint Form and Procedures The City has developed aTitle V| Complaint Form todocument all complaints received by City and/or contractor staff (Attachment #2). This form is available in English, Spanish and Korean on the Cit«'s vvebsite and from any staff member from the Cit/sshared network folder. The form will also be available via email or US mailed for free upon request.
3. Tracking and Recording Title VI lnvestigatjqn§,�g���� The City will maintain a list of all Title V| and of other nondiscrimination statues investigations, complaints, or lawsuits that pertain to allegations mfdiscrimination on the basis of race, color, religion, gender, age, national origin, disability, marital status, sexual orientation, or military status in City activities and programs. The list will include shall w* The date that the investigation, lawsuit, orcomplaint was filed, w Asummary ofthe aUegadons/s\,
• The status ofthe investigation, lawsuit, mrcomplaint, and • Actions taken by the City in response, or final findings related to the investigation, lawsuit, or complaint.
The list will be maintained by the City Manager's office and an updated copy provided to the Human Resources' office on a periodic basis.
14 City of Downey Transit Services Title V1 Program * May 2022 a
=TITLE V1 COMPLAINT FORM
Complaint form is available in English, Spanish and Korean either online, at the Transit Cent from City Hall or (upon request) by mail or email. I
0 City-)[ , Downey
Title V1 Complaint Form
As required by the Federal Transit Administration (FTA) and as set forth in Title V1 of the Civil Rights Act of 1964:
"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. 2000d) If you believe you have been the target of discrimination on the basis of race, color, national origin, religion, gender, age, disability (handled through a separate the ADA complaint and grievance procedure), marital status, sexual orientation, or military status, please complete this form in as much detail as possible. This completed form must be submitted within 180 days of the incident. If i form for anv reason. olease co
Section 1:
Name:
Address:
Telephone (Home): Telephone (Cell):
Email Address:
Section III:
Are you filing this complaint on your own behalf? ElYes No If you answered "Yes," go to Section I II
If you answered "No":
Please supply the name and relationship of
the person for whom you are filing this
form:
Explain why you have filed
for a third party:
Have you obtained the permission of the aggrieved party? El Yes E] No Section IW
I believe the discrimination experienced was based on (check all that apply);; 0 Race 1:1 Color EINational Origin 1:1
Other*
Date of Alleged Discrimination (Month, Day, Year):
16 City of Downey Transit Services Title V1 Program a May 2022 Explain as clearly and completely as possible what happened and why you believe you (or another) were discriminated against. Describe all persons who were involved. include the name and contact information of the person(s) who discriminated against you (if known) as well as names and contact information of any witnesses. If more space is needed, please attach additional sheets.
Section IV:
Have you previously filed a Title V1 complaint with this agency? 0 Yes [3k10 Section V:
Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or State court? [] Yes C-] No
If yes, check all that apply and list the agency's name:
C] Federal state Agency
Agency
Federal Court State Court
Local Agency Other
Please provide information for the contact person at the agency/court(s) where the complaint was filed. (Please attach additional sheets if more than one agency/court.) Please attach any written materials or other information that you think is relevant to your complaint.
Signature and date are required.
Signature Date
Please submit this form in person at the address below, or mail this form to:
City Manager's Office
11111 Brookshire Ave,, 31'� Hoor
Downey, CA 90241
(562) 299-6619
LIST OF TRANSIT�RELATED
TITLE VI INVESTIGATIONS,
18 City of Downey Transit Services Title V1 Program * May 2022 1r4n, -&-m IFTIUMM
As of May 2022, one complaints or lawsuits have been filed against the City of Downey Transit Services.
Complaints
- — ------- — - - — - - - --------------------
Date Type of Alleged Name of Complainant Status
Action Taken
Complaint Discrimination
Received
10.2.2019 - Emailed
10.2.2019 Race ID: 001 CLOSED
Complaint to Caltrans
10.3.2019 - mailed
complaint to ETA
10.2.2019 - No
discrimination was found
per staff, Complainant felt
the delay for pickup was
based on her race. Staff
explained to Complainant
regarding transit
operations.
10. 11.2019 — Staff sent
letter to complainant with
update and to follow up
with FTA with uestions.
Investigations
Date Type of Alleged Name of Target of Status Resolution/Action Taken Investigation Discrimination Alleged Discrimination
Commenced
------ - -----
a �• •• t
PUBLIC PARTICIPATION PLAN
21 City of Downey Transit Services Title V1 Program e May 2022 Downey Transit Services' Public Participation Plan has been designed tohelp ensure that no one is prevented from participating in key issues in DOxxne»'s1ranSpOrtation planning efforts, such as fare increases or service modifications. The goal is to bring all stakeholders into the decision -making process so the City Council can make an informed decision in regards to the City's transit services.
The City plans to continue to directly reach out to the community through the dissemination of flyers, advertisements in local newspapers, articles on the City's website, Instagram posts, and The Orbit community guide book and at local events. COVID Note: At the time of writing, some City in -person services and events remain suspended due to COVID. The following reflects both the outreach that has been undertaken as well as how outreach will resume once all COVID restrictions have been lifted.
Flyers, BroqchhyutregjsAaqn4d���
Brochures for both Downev, LINK (,English and SQa
distributed at various sites throughout the City including ibraries, the senior center and the community center. Information on both services is also included in the Parks and Recreation catalog that is mailed to all Downey residents.
In addition, bi-annual mailings will be sent to community organizations that directly serve LEP, low income, and senior populations inDowney. These organizations will beasked 10work with the City Manager's Office to ensure that their attendees are aware of and able to access all transportation and other services. Currently, the community outreach list includes:
— Food and nutrition programs including food pantries,
— Churches that offer services inlanguages other than English (including Spanish, Korean, — Church programs that have special programs for the deaf and seniors, — Medical programs inc|udingfrep/|ovv cost clinics,
— Senior residences, and
— Other programs that serve low-income residents.
Public Information Meetings
The City periodically conducts public meetings to explain changes or proposed changes to Downey Transit prior to City Council consideration. These meetings serve as a means to engage the public and to provide input for future service changes and are conducted at public facilities such aslocal community and senior centers. These public workshops are brainstorming sessions
and they provide vital information that can be used to assist in the improvement of the City's transit programs and in potential identification of LEP populations that may be in need of assistance.
i nese worK nOpS Wifr== i - U - -
for accessibility and at various times of the day and week to ensure that all community stakeholders are part of the decision -making process. When possible, bilingual Spanish -English staff will attend the event to facilitate participation by limited -English Spanish-speaking residents. Special effort will be made to hold workshops in at least one location (e.g. a church) that directly serves the Korean population in Downey. It is expected that staff from the community organization will be able to serve as translators for any LEP individuals who attend these meetings.
Participation in Community Events
The City participates in community events in order to promote its transit services. These transit information, including schedules, brochures and flyers.
When the City is proposing a material change to the transportation services (including such changes as permanent route adjustments, fare increases, or substantial service modifications), staff will inform the public of the proposed changes with a minimum of 30 days and up to four months' notice, depending on the level of service change.
For any changes that require City Council approval, Downey will allow the public to comment Z-C-k
Council.
In accordance with the City's policies and procedures, the City will continue its current notification outreach efforts. in addition, specifically in the public comment window prior tt ?ny fare or substantial service changes to the transit programs, the City will continue to:
• Post English and Spanish notices on all vehicles for the impacted service • Hand out notices to all riders (bilingual Spanish/English) • Mail notices to the community outreach mailing list
• Post notices at the Transit Station
Whenever possible, when staff prepares a document or schedules a meeting for which the may be made available in Spanish (based on available resources). Every effort will be made to have Spanish and, upon request, Korean interpreters available as well for meetings that invite public comment on Transit issues.
23 City of Downey Transit Services Title VI Program * May 2022 The City of Downey and its transit provider will ensure that no person, on the grounds of race, color or national origin, as provided by Title VI of the Civil Rights Act of 1964, will be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination in the use of the City's transportation services (both contracted and otherwise). Further, the City and will take preventive corrective and disciplinary action necessary to stem behavior that violates the rights and privileges the regulations are designed to protect. The City will post this information on its web site and ensure that it reflects up to date information consistent with the requirements of Title VI.
The City's Title VI Plan and Procedures, as well as the Language Assistance Plan, are available or the City of Downey's website at www.downeyca.org . Any person or agency with internet access will be able to access and download the plan from the City's website. Alternatively, any person or agency may request a copy of the plan via telephone, email, standard mail, or in person and shall be provided a copy of the plan at no cost.
Questions or comments regarding the Title VI or Language Assistance Plan may be submitted City Manager's Office
Downey, CA 90241
ATTACH M ENT 6
LANGUAGE AssiSTANCE PLAN
25 City of Downey Transit Services Title VI Program * May 2022
CITY OF DOWNEY TRANSIT SERVICES
TITLE VI LANGUAGE ASSISTANCE PLAN
May 2022
The Language Assistance Plan has been prepared to address the City of Downey's responsibilities as a sub -recipient of federal financial assistance as they relate to the needs of individuals with limited English language skills. The plan has been prepared in accordance with Title VI of the Civil Rights Act of 1964 and Federal Transit Circular 4702.113, which state that no person shall be subjected to discrimination on the basis of color, race, and national origin. In addition, Executive Order 13166, titled "Improving Access to Services for Persons with Limited English Proficiency", indicated that differing treatment based upon a person's inability to speak, read, write or understand English is a form of national origin discrimination. It directs each federal agency to publish guidance for its respective recipients clarifying their obligation to ensure that such discrimination does not take place. This order applies to all State and local agencies that receive federal funds.
both are contracted to MV Transportation. The Downey City Council is the policyrnaking body of the system. The Council makes decisions based on advice received from the public, the City's departments, advisory boards and commissions. Transit services in the City of Downey consist of a fixed -route service (Downey LINK) and a demand -responsive Dial -A -Ride service. The City of Downey has developed a city-wide Language Assistance Plan to help identify reasonable steps for providing language assistance to persons with limited English proficiency that wish to access services. As defined by Executive Order 13166, LEP persons are those who do not speak English as their primary language and understand English "less than very well." This transit -specific plan addresses the specific needs of transit users and helps to clarify how the city-wide plan will be implemented for this department. This plan outlines ways to identify a person who may need language assistance, the ways in which assistance may be provided, and how to notify LEP persons that assistance is available. In order to prepare this plan, City of Downey Transit Services staff performed the U.S. Department of Transportation' s four -factor LEP analysis, which considers the following factors:
1. The number Orproportion ofLEP persons inthe service area who may beserved orare likely to encounter the City of Downey's transportation programs, activities, or services.
2. The frequency with which LEP persons come in contact with City ofDowney transportation programs, activities, orservices.
]. The nature and importance ofprograms, activities orservices provided bythe City of Downey transportation services tothe LEP population.
26 City of Downey Transit Services Title V! Program a May 2022 MIMM89���
Factor 1: The number or proportion of LEP persons in the service area who may be served or are likely to encounter transportation services, programs, or activities that are offered by the 29���
City of Downey staff reviewed ACS data from the 2019 United States Census Bureau and determined that 21% (21,821) of the City's population has limited English proficiency; that is, they speak English "less than very well." Of this LEP group, 83% (18,182) are Spanish speakers and 1.2% (1,217) speak Korean.
Based on the information mentioned above, it is clear that Spanish is the primary language spoken by LEP individuals in the City of Downey who may be served or are likely to encounter transportation services, programs, or activities that are offered by the City. 571: 1
in this Language Assistance Plan. However, the City will monitor demographic trends using data from the US Census Bureau and will survey frontline staff on the language needs of the City's transportation program patrons. For all languages, the City will endeavor to identify and network with local and neighboring organizations and services to provide as much language assistance as possible.
Factor 2: The frequency with which LEP persons come in contact with City of Downey transit programs, activities, or services.
A high proportion of Spanish speakers come into contact with the various transit programs th are offered by the City. In the Transit division's recent survey, contract and City trar i Factor 3: The nature and importance of programs, activities, or services provided by the City of Downey Transit to LEP populations.
The City of Downey's transportation services and programs are essential to all City residents. In a pre-COVID-19 pandemic study, it was determined that over half of the Downey LINK riders are 04 other transportation providers for their work commute. In a review of pre-COVID-19 pandemic Dial -A -Ride data, the most common destinations are for medical appointments, the senior center (including congregate meal program), personal errands (banking, shopping), school or other educational sites, work, and religious sites. Given that these services are vital to the entire body of riders, 'it follows that the services are critical to the LEP community as well.
27 City of Downey Transit Services Title VI Program 9 May 2022 provide LEP assistance.
A significant number of City staff are bilingual English/Spanish and provide a critical resource for serving LEP Spanish speakers. In addition, K4VTransportation (the contract provider for both the demand -responsive and fixed -route contract provider) commonly serves Spanish-speaking clients in Downey and the surrounding Los Angeles area cities. Providing bilingual interpreter atpublic hearings, transit focus groups, etc. might require a small amount of additional staff time. There are also a number of organizations and nonprofits in Downey that provide services in English and Spanish who could also assist with outreach and service access.
The resources to provide additional LEP assistance for Korean speakers are significantly less. We have been unable to identify any Korean assistance or social organizations in Downey. The closest Korean Social Service organization is in Buena Park. We have been able to identify two Korean churches orreligious services. This seems toindicate that the Korean community's focus for social and cultural activities is outside of Downey (possibly in cities like La Mirada or La Habra which have much larger Korean populations). As a result, it is expected that any translation activities will be through a private fee -for -service organization. Phone interpretation prices are expected to be $3 per minute. Translation of written materials will depend on the final word count of each piece. And estimated price is $0.18 - $0.35 per word.
Based onthe four -factor analysis, the City ofDowney developed its Language Assistance Plan aa outlined inthe following section.
Langtliage Assistance, Plan,
Downey Transit Services has developed several possible ways to assist in identifying LEP populations within the City, including:
Examine records tosee ifrequests for language assistance have been received inthe past, either at meetings or over the phone, to determine whether language assistance might be needed at future events or meetings.
2. Conduct annual Transit staff surveys to track LEP issues and needs.
3. Network with local nonprofit and social service agencies to assist in identifying LEP groups and individuals most in need of LEP assistance and to further facilitate dissemination of information about the City's transit services and programs. For example, staff have identified more than a dozen churches that provide services in Spanish. Staff have also found churches that offer services and ministries for Korean, Armenian, Eritrean, Greek Indonesian, and Arabic speakers. Other public and nonprofit programs that serve low income residents (e.g. WYA<]F senior and childcare services, county housing offices, and free
28 City of Downey Transit Services Title V1 Program * May 2022 and low-cost medical clinics) will also be important in identifying and linking LEP residents to transit services.
4. Have City staff greet participants as they arrive at events and meetings sponsored by the City's Transit Services. By informally engaging participants in conversation it is possible t# identify LEP individuals who may need language services.
Language Assistance Measures
The Spanish-speaking population has had a significant presence in the City's transportation program's service area for a long time; therefore it has been important to offer materials in formats that are easily understood by this population, including:
• Dial -A -Ride Applications and Service Brochures are available in English and Spanish • The Downey LINK schedule and route map contains information in English and Spanish • When possible, ensuring that at least one Dial -A -Ride reservationist on duty is bilingual Spanish/English. In the occasional instance that a bilingual reservationist is not available, the staff has sufficient Spanish and training to effectively handle the call. (Downey has had no reports of LEP Spanish speakers being unable to schedule the rides they need.) In addition, the above community resources will be used on a regular basis to assist in identifying the needs of the City's LEP community. They will also serve as a means to widely fisseminate bilingual transit information and announcements, and to notify the LEP population *f planned meetings and outreach efforts.
There are plans for a number of language assistance options available to the LEP community, including both oral and written language services. There are also various ways in which the City's Transit Services staff can respond to LEP persons, whether in person, by telephone, or in writing. These options include:
* As resources allow, the City will have bilingual Spanish/English staff at Transit booths at community events and at Transit focus groups. The City will also make every effort to have bilingual staff made available to community nonprofit and social services groups for informational presentations.
* Vital printed documents, including fixed -route schedules, Dial -A -Ride service information brochures and applications, Title VI notification of Rights ., and Title VI Complaint Forms, will be available in English and Spanish on the City Website. They will also be printed in Korean if requested and as resources allow. If not translated they will, at minimum, also carry a statement in Korean and English providing a contact number for LEP individuals to call to request information in a language other than English. 0 Notices of substantial service changes, including fare increases and permanent route changes, will be posted in English and Spanish (on the schedule and in the locations indicated in the "Public Participation" section) and mailed to all identified community networking organizations (e.g. churches) who serve other LEP populations. Public hearings before the City Council will include bilingual Spanish/English staff who can
29 City of Downey Transit Services Title VI Program * May 2022 provide translation services for individuals wishing to comment. City will also make every effort tohave Korean translators available ifrequested. • Annual discussion/survey of drivers and other frontline staff, e.g. dispatchers and Dial -A- Rideschedu|ers,ontheirexperienceconcerning any contacts with LEPpersons during the previous year, to see if additional language assistance measures are needed. • Posting of the City of Downey's Title VI Policy and Language Assistance Plan on the City's City of Downey strives to adhere to the Safe Harbor Provision, the City's transportation department operates from a limited budget — making it financially prohibitive to translate all vital documents into every language of persons eligible to be served or likely to encounter our transportation services. However, the city-wide Language Access Plan clearly states that the City will respond to any specific request regardless of the size to the LEP population. To that end, the City is contracting with a telephonic translation service for all City programs and has created a "Point to your language" sign which will be available at public counters throughout the city.
For Transit programs, the demographic served b«the City ofDoVvn*«'stransportation department falls primarily within the Spanish-speaking community. AS8result, all vital documents are translated into Spanish and the contract provider is required within their contract tobeable tmserve LEPSpanish-speaking clients.
The City of Downey will update the Language Assistance Plan as required by US DOT or when it is clear that higher concentrations QfLEP individuals are present in the [ity'stran6it service area. Updates tothe Language Assistance Plan will consider:
• How the needs ofLEPpersons have been addressed;
• The current LEPpopulation inthe service area;
• Determination as to whether the need for translation services has changed; and, • Whether complaints have been received concerning the Cbv'sfailure tomeet the needs qfLEP individuals.
1 t i
31 City of Downey Transit Services Title V1 Program a May 2022
CITY OF DOWNEY
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Downey LINK operates Monday through Friday from 6:30am to 6:30pm. Saturday service is available (with the same routes and schedules) during the holidays from the Saturday after Thanksgiving until the Saturday before Christmas. Downey LINK does not operate on the following holidays: New Year's Day, Memorial Day, Independence Day, Labor Day, ThanksgiviJ� �N Day, Christmas Eve and Christmas Day. I
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Vehicle load is expressed as the ratio of passengers to the total number of seats on a vehicle, Based on vehicle characteristics, the City has established a maximum load factor of 1.25 to ensure the comfort and safety of passengers.
Downey Link fixed -route service operates weekdays from 6:30 a.m. to 6:30 p.m., with four separate routes: Southeast, Southwest, Northeast, and Northwest. Regular headways are approximately 50 minutes, with additional Tripper service scheduled to accommodate peak demands. From 9 a.m. to 2 p.m., routes are combined to form a South and a North route, which results in approximately 100-minute headways.
Among the most important service standard for customers is on -time performance or adherence to the published schedules.
Definition of "On Time' � The City considers any run that is between 0-5 minutes after the scheduled departure time to be "on time."
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ScheduJ6 Refi4bil . The contract with MV Transportation identifies the acceptable on -time performance as 90% of bus departures.
312 City of Downey Transit Jervices Title V! Program a "Olay M- 7RZ-7-mumn-10
The Downey LINK service comprises four one -directional loops that intersect with each other as well as with other fixed service providers (including the Metro Green Line and Metro buses).
The four routes total 104 stops, some of which are used by more than one line. The average distance between stops is approximately Y2mile. Stops are distributed with the goal of ensuring that all Downey residents are within one mile (as measured by available walking paths, not straight line) of a stop. The majority of residences are within Y2mile of a stop.
Downey LINK stops are distributed across the city and provide access to major medical centers, social services, schools, cultural/historic sites and major transit corridors. Downey LINK also provides convenient access to the Metro Greenline station to encourage and support South Coast Air Quality Management District (SCAQMD) trip reduction efforts. All loops begin and end at the Downey Depot which is located in the heart of the city and a short walk from City offices and businesses. Nearly all primary and secondary schools, all hospitals, and all community/senior centers are located on — or within a short walk — of a Downey LINK stop.
Transfers between Downey LINK routes are free.
The City of Downey's policy related to transit amenities is to ensure equitable distribution of items that promote safety, comfort, and convenience across the entire fixed -route system without prejudice. As such, all riders have equal access to the amenities provided by the City for the Downey LIN K fixed -route service.
Seating and shelters are installed at various high usage locations along the route where it is legal and permitted in consistency with the City s and ADA stan ar s an regulations. Seating and shelters are installed in an equitable manner to serve all community members wishing to utilize them. Seating and shelter locations are identified by City staff working in the Parks and Recreation and Public Works departments. Requests from the public 4- S. All
and comments received during public input process are considered in Lhese determination tA seating and shelters are installed in a manner that promotes safety, comfort and convenience.
Provisinn nf PrintPd Signs, System M;;nr, ;;nrl Schedules. Thi-s inforMatinn is distrihiqPH tn thp public with the intent to promote and explain the City's fixed -route system. The information is intended to educate the community as to the availability of the service and is made available in various formats. Electronic versions of the material are distributed via the City website. Printed versions of the information (in English and Spanish) are available to all members of the community and are distributed on buses, at the Downey Depot, at community events and, by request, at other community sites.
Vehicle Assignment
Pr77—TTrF'MWTZWfE =Fre assigneu MUM Dal, ZY MUM Eo a rUTMr.YATYiee-E olf Se',ren LINK buses are all the same in age, size, and capacity.