09. Adoption of Updated Citywide Language Access Plan and Title VI Program-Transit

Item No.

TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM: OFFICE OF THE CITY MANAGER
BY: SHANTAE DUREN, MANAGEMENT ANALYST
D ATE: MAY 27, 2025
SUBJECT: ADOPTION OF THE UPDATED CITYWIDE LANGUAGE ACCESS PLAN

AND CITY TITLE VI PROGRAM - TRANSIT

EXECUTIVE SUMMARY
The City Council will consider adopting the updated Citywide Language Access Plan and the City of Downey Title VI Program-Transit. A citywide language access plan is a document that outlines how a city will provide communication assistance services to individuals who are non-English speaking, have limited English proficiency (LEP), or have communication disabilities. Downey’s Citywide Language Access Plan has been updated to include current language access efforts throughout all City departments, Additionally, Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or national origin in programs and activities receiving federal financial assistance, including public transportation. Transit agencies receiving federal funds, such as the City’s Downey Link and Dial-A-Ride systems, are required to implement a Title VI program that ensures non-discriminatory services and benefits. This includes developing public participation plans, providing meaningful access for limited English proficient individuals, and addressing complaints of discrimination. This plan is required to be updated every three years. The City’s updated Title VI Program-Transit incorporates a specific review of transit-related efforts and feedback from transit staff, together ensuring fair access to all City services for residents, including those with limited English proficiency.

RECOMMENDATION
That the City Council:

Adopt the updated Citywide Language Access Plan and the City of Downey Title VI Program-Transit.

BACKGROUND
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

APPROVED BY

CITY MANAGER

ADOPT THE UPDATED CITYWIDE LANGUAGE ACCESS PLAN AND CITY TITLE VI PROGRAM –

TRANIST
MAY 27, 2025
PAGE 2

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.

While 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 an FTA regional civil rights officer, in this case Metro, once every three years or as otherwise directed.

ANALYSIS

The City’s Title VI Program – Transit is due for its tri-annual update this month, May 2025.

City staff has worked with a consultant to review its current language access plan efforts related to 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 per the FTA, such as: the notice of the public’s rights, instructions on how to file a complaint, and the Public Participation and Limited English Proficiency Plans. City staff also made minor modifications to the Plan including removing outdated information, updating contact information for the U.S. Department of Homeland Security (DHS), and the U.S. Department of Transportation, Federal Highway Administration, Office of Civil Rights (FHWA OCR), reporting the addition of a new bus stop, updating the City of Downey Title VI Complaint Form to remove the requirement for signature, and updating current language access efforts, which include transit services participating in community events with a table dedicated to transportation and providing bilingual transit information.

Additionally, as part of the Title VI Program – Transit update process, City staff also made minor modifications to the Citywide Language Access Plan (Attachment A). These minor changes include, removing outdated information, updating complaint information, updating contact information for DHS and FHWA OCR, updating the City of Downey Title VI Complaint Form to remove the requirement for signature, and updating current language access efforts to include the addition of multiple exhibit descriptions being translated to Spanish at the Columbia Memorial Space Center and the offering of one CERT training in Spanish every year.

ADOPT THE UPDATED CITYWIDE LANGUAGE ACCESS PLAN AND CITY TITLE VI PROGRAM –

TRANIST
MAY 27, 2025
PAGE 3

To ensure that all residents are given equitable access to City services and provided opportunities for engagement (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 Plans.

CITY COUNCIL PRIORITIES

Quality of Life, Safety & Infrastructure
Public Engagement

FISCAL IMPACT

There is no fiscal impact to adopting the Citywide Language Access Plan and Title VI Program -Transit. However, there could be expenses related to outreach efforts such as, multi-language flyers and displays highlighting City services and programs, and translation and interpreting services when requested by members of the public.

ATTACHMENTS

Attachment A – Citywide Language Access Plan
Attachment B – Title VI Program - Transit

CITY‐WIDE
TITLE VI PROGRAM:

LANGUAGE

ACCESS PLAN
Revised May 27, 2025
This document sets forth policies and procedures to effectively monitor and ensure that the City of Downey is in compliance with Title VI of the Civil Rights Act of 1964 as required by law and in keeping with the guidance documents developed by the US Federal Agencies from which the City receives funding.

ATTACHMENT A

DOWNEY CITY‐WIDE TITLE VI PROGRAM

TABLE OF CONTENTS

I. Introduction ............................................................................................................................................... 1

II. Title VI Language Access Plan (LAP) ......................................................................................................... 1 A. Notifying Beneficiaries of Protection under Title VI ......................................................................... 1 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

III. Attachments
Attachment 1: Title VI Complaint Form ............................................................................................ 8 Attachment 2: Title VI Complaint Log ..............................................................................................11

IV. Appendices: Federal Agency-specific Requirements
Appendix 1: Department of Homeland Security ..............................................................................14 Appendix 2: Department of Justice ..................................................................................................17 Appendix 3: Institute of Museum and Library Services (IMLS), National Foundation on the Arts and the Humanities ..................................................................................................................................20 Appendix 4: Housing and Urban Development ...............................................................................22 Appendix 5: Federal Transit Administration ....................................................................................24

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 1 I. INTRODUCTION
The City of Downey is proudly committed to continuously improving the quality of life for the Downey community by providing excellent service in a professional, ethical and responsible manner.

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 reflected in this Citywide Language Access Plan (Title VI Program). As required by Federal regulations 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:

"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)

Though this Language Access Plan addresses Title VI requirements, Downey is nonetheless committed to regulatory requirements other nondiscrimination statutes that afford legal protection, including: 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).

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. 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, May 24, 2022 and May 27, 2025).

II. TITLE VI CITYWIDE LANGUAGE ACCESS PLAN
A. Notifying Beneficiaries of Protection under Title VI In order to comply with 49 CFR, Section 21.9(d), the City shall provide information to the public regarding the City’s obligations under the Title VI regulations and apprise members of the public of the protections against discrimination afforded to them by Title VI.

The City of Downey will inform members of the public of their Title VI protection in a variety of ways, including:
• On the City’s website at http://www.downeyca.org/titleVI (The Website also includes a link to translate the webpage into Spanish)
• On City agendas, which are printed in both Spanish and English; • Posting of notices inside all Dial‐A‐Ride and Fixed‐Route vehicles; • 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.

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 2 B. Language Services/Resources Available for Staff to Provide Access for LEP Individuals 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 Interpretation
a. Oral Interpretation Resources
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 been tested*; • 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 b. Timing of Interpretation
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.

2. Written Translations
a. Spanish

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 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 II, Part C, Criteria to Identify “Vital Documents”).
b. Korean
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 languages other than Korean or Spanish. For vital documents, the city will provide written translation of forms if requested by LEP individual.

C. Criteria to Identify “Vital Documents”
The City has determined that the following factors will be used to guide staff in their classification of a document (form or information brochure/sheet) as vital. Staff will be asked to consider that the following factors when classifying documents:

1. Forms that are required to be completed before the LEP individual may access a City service, for example:
• Library card applications
• Application or registration forms
• Intake forms

2. Commonly used forms or public outreach materials that seldom change and are central for important services or that commonly result in fines or may have other financial impact, for example:
• Yard Sale Permits

3. Mechanisms by which the public participates in City governance and planning, for example:
• Service surveys/feedback forms
• Notices of public briefings or focus groups

4. Service announcements and materials that serve as the principal outreach mechanism.

Since “lack of awareness that a particular program, right, or service exists may effectively deny LEP persons meaningful access,” staff will regularly assess 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 version.

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 4 D. Policy on Use of Family and/or Friends for Oral Interpretation 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 or family member when accessing City services.

The City respects the LEP individual’s right to select their own interpreters. However, the City also recognizes its responsibility to ensure that LEP individuals make an informed choice. Therefore, a notice in English, Spanish, and Korean will be posted at public counters 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;
• 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 or by phone;
• disseminating flyers or notices through the schools;
• and distributing outreach materials, including the use of social media.

F. Title VI Complaints
The City of Downey takes allegations of discrimination of any kind very seriously. Three specific categories of discrimination fall under Federal Title VI 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 VI complaints filed against the City and to make these procedures for filing a complaint available to the general public.

The City has developed the following Title VI complaint procedures. Both the complaint procedures and the complaint form will be posted in English, Spanish and Korean on 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.)

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 5

1. City of Downey Title VI Complaint Procedures
(a) Submission of Complaint
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 complaint procedures will be available in English, Spanish and Korean. (b) Investigation of Complaints
Once filed, the City Manager’s Office, or its designee, will investigate the complaint. The investigation may include discussion(s) of the 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, the City may administratively close the complaint. A reasonable extension may be provided 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 10 business days of receipt of the complaint.
(c) Resolution of Case
After the investigation of the complaint is completed, the City will issue one of two 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 of a Title VI 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 be taken, including discipline or additional training of the staff member, contract staff, etc. (d) Request for Reconsideration
The Letter of Finding will also notify the complainant of his/her right to submit a request for reconsideration regarding the results of the investigation. If the complainant disagrees with the City’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 10 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

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 6 If the request for reconsideration is denied, the complainant may appeal that decision by submitting a written request to the City Manager for final determination. (f) Submission of Complaint to the Federal Department
Complainant may, at any time, submit the complaint directly to the relevant Federal Department for investigation, including:
• U.S. Department of Transportation, Federal Transit Administration‐ Office of Civil Rights, Attention: Complaint Team, 8th Floor – E81‐105, 1200 New Jersey Avenue, SE, Washington, DC 20590. (In accordance with Chapter 9, Complaints, of FTA Circular 4702.1B, such a complaint must be filed within 180 calendar days of the date of the alleged discrimination.
• U.S. Department of Transportation, Federal Highway Administration, Office of Civil Rights, 1200 New Jersey Avenue, SE, 8th Floor E81‐105, Washington, DC 20590. (202)366‐0693, [email protected]
• U.S. Department of Housing and Urban Development, One Sansome Street, Suite 1200, San Francisco, CA 94104, (415) 489‐6400
• U.S. Department of Justice, 950 Pennsylvania Avenue, NW, Washington, DC 20530‐ 0001. (202) 514‐2000
• US Department of Homeland Security, Office for Civil Rights and Civil Liberties, Review and Compliance Branch, Mail Stop #0190, 2707 Martin Luther King Jr. Ave SE, Washington, DC 20528‐0190. (866) 644–8360, Toll Free TTY: (866)644–8361, Fax:
(202) 401–4708, [email protected].

2. Ensuring Easy Access to Complaint Form and Procedures 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.

3. Tracking and Recording Title VI Investigations, Complaints, and Lawsuits.

The City will maintain a list (Attachment #2) of all Title VI and of other nondiscrimination statues investigations, complaints, or lawsuits that pertain to allegations of discrimination 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 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.

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. Since May of 2022 through May 27, 2025, the City of Downey has had one Title VI –complaints, investigations, or lawsuits. (This complaint was incorrectly filed with the City against a local, privately‐held newspaper which has no connection with the City.)

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 7 G. Staff Training
The City will take steps to ensure that all staff and Department Heads – not just those from “front 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;
• 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 included in the onboarding for 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 do 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 A

Downey City-Wide Language Access Plan rev. May 2025 8 ATTACHMENT #1

≡ TITLE VI COMPLAINT FORM ≡

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 9

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 10

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 11 ATTACHMENT #2

≡ TRACKING OF TITLE VI

INVESTIGATIONS, COMPLAINTS
AND LAWSUITS ≡

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 12 City of Downey
Tracking Title VI Investigations, Complaints and Lawsuits

Complaints
Date Complaint
Received
City
Department/Division
Involved
Type of Alleged
Discrimination ID of Complainant Name of Target of
Alleged Discrimination Status Action Taken
6/14/2022 City Clerk Civil Rights ID: 002 Herman City CLOSED

6.16.22 – Sent letter that there was no
discrimination on the part of the City for
what is printed in the Downey patriot
and opinions shared in. The Clergy
Council was dissolved as a City advisory
body.

Investigations
Date of Original
Complaint
Date Investigation
Commenced
Type of Alleged
Discrimination
Name of Target of Alleged
Discrimination Status Resolution/Action Taken

Lawsuits
Date Lawsuit
Filed
Type of Alleged
Discrimination
City
Department/Division
Involved
Name of Person who Filed
Suit Status Resolution

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 13

APPENDICES OF AGENCY SPECIFIC REQUIREMENTS

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.

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 14 APPENDIX #1

AGENCY SPECIFIC REQUIREMENTS

DEPARTMENT OF HOMELAND SECURITY

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 15 I. Downey Police Department

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 Justice section).

II. Downey Fire Department

A. Fire Dispatch
Through a contract provided by the California Office of Emergency Services, the dispatchers in the Joint Communication Center which dispatches for Downey Fire have access to the City’s telephone and on‐demand video interpretation services for any LEP calls. Dispatchers are trained to connect with and work through the telephonic service.

B. Emergency Medical Services
EMS staff carry tablets in their emergency vehicles and have installed Google Translate to assist in emergency situations. Through a City contract, staff also have access the same telephone and 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 the information needed to practice fire safety, including:

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
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.)

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. Downey provides the Basic CERT Training in Spanish once a year.

D. DHS-related Complaints
In addition to the city‐wide Title VI complaint procedures outlined in section II F, complaints

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 16 alleging that the City has failed to provide meaningful access to programs and services for LEP persons may also be sent to the DHS CRCL in any language to:

By Mail:

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.

Telephone/Fax:

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.

E-mail Address:

[email protected]

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 17 APPENDIX #2

AGENCY SPECIFIC REQUIREMENTS

DEPARTMENT OF JUSTICE (DOJ)

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 18 I. Downey Police Department
The Downey Police Department is committed to protecting the lives, property and rights of all 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, being bilingual in Spanish or Asian languages is desirable when hiring 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.
• For enforcement stops short of arrest and field investigations, 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.

B. Selection of Oral Interpreters
Downey Police Department currently offers the opportunity for officers and staff to take bilingual certification tests in Spanish and several other languages. For steps 1 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 member/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 interpreter), and the severity of the issue. If there is any question of the appropriateness of using informal interpreters, officers are instructed to call the professional telephonic interpretation service.

C. Community Outreach and Involvement
The Downey Police Department recognizes the importance of outreach to the LEP community.

It is a priority of the PD to not only recruit bilingual officers, but also key staff who can assist with outreach and coordination with LEP populations.

1. Explorer Program
To encourage participation by bilingual individuals, Explorer outreach materials will be

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 19 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 department’s current Neighborhood 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 handout 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.

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 20 APPENDIX #3

AGENCY SPECIFIC REQUIREMENTS

INSTITUTE OF MUSEUM

AND LIBRARY SERVICES (IMLS)

NATIONAL FOUNDATION ON THE ARTS AND THE HUMANITIES

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 21

I. The Downey Library
The Downey Library has in place a number of services and resources for LEP individuals.

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
• Children’s program fliers
• Adult literacy program
• Online Library catalog

B. Collections/Holdings
The Downey Library has existing Spanish and Korean language collections. Signs in Korean and Spanish provide clear visual indication that these holdings are available.

C. Volunteer Recruitment
To encourage participation by bilingual individuals, information on Library volunteer opportunities will be included in materials circulated to community partners.

II. Columbia Memorial Space Center

A. Volunteer Recruitment
To encourage participation by bilingual individuals, information on docents and museum volunteer opportunities will be included in materials circulated to community partners.

B. Exhibit Translation
Currently, several of the museum’s exhibits have Spanish translations, with additional exhibits in progress of being translated into Spanish.

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 22 APPENDIX #4

AGENCY SPECIFIC REQUIREMENTS

HOUSING & URBAN DEVELOPMENT (HUD)

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 23 I. Annual Action Plan Development for CDBG and HOME Programs 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. Community Meetings
In order to encourage the greatest possible participation of all elements of the community – including LEP individuals – the Housing Division offers community meetings at various times and locations. Announcements of these meetings will be posted in English and Spanish (with the key information translated into Korean, including meeting title, date and location and how to request a full translation). Notices will carry a statement that telephonic and on‐demand video interpretation is available upon request and with advance notice.

2. Draft and Final Plans
Any drafts and final plans which are made available to the public will be translated into Spanish and circulated to community partners and any resident who requests to receive the draft and final plan. In keeping with the City‐wide Title VI plan, Korean or other language translations may be requested.

II. Affirmative Outreach
The Housing Division 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 on the City website and social media;
• posting bilingual outreach materials in City buildings; and, • circulating outreach materials about services, programs and community meetings to the City’s community network. The community network comprises those local organizations that are most likely to provide services for low income and/or LAP individuals (e.g. churches, food banks, school district, adult school, etc.)

ATTACHMENT A

Downey City-Wide Language Access Plan rev. May 2025 24 APPENDIX #5

AGENCY SPECIFIC REQUIREMENTS

FEDERAL TRANSIT ADMINISTRATION (FTA)

Note:

The FTA has specific requirements for a Title VI plan for the City’s Transit Services. An updated Title VI 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.

ATTACHMENT A

TRANSIT SERVICES

TITLE VI PROGRAM
Revised May 27, 2025
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

DOWNEY TRANSIT SERVICES TITLE VI PROGRAM

TABLE OF CONTENTS
I. Introduction ................................................................................................................................. 1 II.Title VI Requirements
A.Requirement to Notify Beneficiaries of Protection under Title VI ............................... 1 B.Requirement to Develop Title VI Complaint Procedures and Complaint Form ........... 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 Planning/Advisory Board ................................................ 4 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 III.Attachments
Attachment 1: Notice of Civil Rights ................................................................................... 5 Attachment 2: City-wide Title VI LAP Excerpt: Complaint Process ................................... 10 Attachment 3: Title VI Complaint Form ............................................................................ 14 Attachment 4: List of Transit Related Title VI Investigations, Complaints, and Lawsuits . 17 Attachment 5: Public Participation Plan ........................................................................... 19 Attachment 6: Title VI Language Assistance Plan ............................................................. 23 Attachment 7: System-Wide Standards and Policies ........................................................ 29

ATTACHMENT B

1 City of Downey Transit Services Title VI Program • May 2025

I. INTRODUCTION

The City of Downey is a place 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, or military status. This commitment to inclusion and service is reflected in the Title VI Program of Downey’s Transit Services. As required by the Federal Transit Administration (FTA), Federal Highway Administration (FHWA), 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 transit services, specifically:

To ensure that all residents are given equitable access to Transit Services and that all citizens are provided an opportunity take part in Transit planning and decision-making (and as a recipient of federal funding), the City of Downey Transit Services will ensure full compliance with Title VI of the Civil Rights Act of 1964.

The Title VI Program-Transit was adopted by the Downey City Council in conformance with FTA C 4702.1B (October 1, 2012, April 26, 2016, May 28, 2019 October 8, 2019, May 24, 2022 and May 27, 2025). 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 VI webpage. No other changes were made.

II. TITLE VI REQUIREMENTS

A. Requirement to Notify Beneficiaries of Protection under Title VI.

In order to comply with 49 CFR, Section 21.9(d), the City shall provide information to the public regarding the City’s obligations under DOT’s Title VI regulations and apprise members of the public of the protections against discrimination afforded to them by Title VI.

The City of Downey will inform members of the public of their Title VI protection in a variety of way, including:
• On the City’s website at http://www.downeyca.org/titleVI (The Website also includes a link to translate the webpage into Spanish);
• On City agendas, which are printed in both Spanish and English; • Posting of notices inside all Dial-A-Ride and Fixed-Route vehicles; and, • Posting of notices in the public area of the Transit Center.

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2 City of Downey Transit Services Title VI Program • May 2025

Copies of notices can be found in Attachment #1.

B. Requirement to Develop Title VI Complaint Procedures and Complaint Form.

The City of Downey takes allegations of discrimination of any kind very seriously. Three specific categories of discrimination fall under Federal Title VI 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.

1. City of Downey Title VI Complaint Procedures

The city-wide complaint procedures can be found in Attachment 2.

2. Ensuring Easy Access to Complaint Form and Procedures

The City has developed a Title VI 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 that 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 VI 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.

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.

The list shall be included in the City’s Title VI submittal to FTA every three (3) years. As of May 27, 2025, the City of Downey had no Title VI – Transit complaints, investigations, or lawsuits since the submission of the 2022 Language Access Plan.

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3 City of Downey Transit Services Title VI Program • May 2025

D. Promoting Inclusive Public Participation.

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 Participation Plan is included as Attachment #5.

Summary of outreach efforts made since the last Title VI Program submission Transit services has changed their principal marketing brochure to create a bi-lingual brochure (Spanish/English) available on the City’s website to ensure that all outreach efforts include LEP Spanish speakers. Transit services have participated in a number of community events such as:

Older Adult Transportation Pop Up Fair, Community and Senior Center Open House, annual Special Needs and Awareness Fair, Metro’s On the Move Riders Program and Public Transit Workshop for Older Adults with a table dedicated to transportation and providing bi-lingual transit information. Also, attendance has been made at community activities such as Senior congregate meal program, community workout classes, and community dinner/entertainment events to share about transit services in Downey. In addition, Downey continues to use 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 Limited 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:
• The number of LEP persons in the service area,
• The frequency that LEP persons come in contact with transit services, • 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 how the City will implement language assistance.

Title VI 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

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4 City of Downey Transit Services Title VI Program • May 2025

Transportation Authority (Metro) and other neighborhood stakeholders to ensure LEP persons have access to necessary information.

The LEP Analysis and Language Assistance Plan are detailed in Attachment #6.

F. Minority Representation on Planning or Advisory Board (not applicable).

The City of Downey does not have a “transit-related, non-elected” planning board, advisory council, or committee. Rather, the City Council serves as the legislative body for all transportation related policy decisions. Therefore, this requirement does not apply to the City of Downey. The city of Downey will follow all Title VI Requirements if a transit advisory council or committee should be formed at an undetermined future date.

G. Determination of Site or Location of Facilities (not applicable).

The City of Downey is not currently using any Federal grants for the construction of any transit related facilities such as storage facilities, maintenance facilities, or operations centers.

Therefore, this requirement does not apply.

H. Requirement to Develop System-Wide Standards and Policies.

FTA requires all fixed-route transit providers to develop quantitative service standards and policies for their fixed-route service.

The City has developed service standards and policies for its fixed-route system consistent with Title VI 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).

I. Obligation to Provide Additional Information upon Request.

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.

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5 City of Downey Transit Services Title VI Program • May 2025

ATTACHMENT 1

≡ NOTICE OF CIVIL RIGHTS ≡
− Text for Website
− 8½ x 11 Flyer for Posting
− DAR Vehicle Cards and
Downey LINK Bus

ATTACHMENT B

6 City of Downey Transit Services Title VI Program • May 2025

Notice of Civil Rights - Website Text
http://www.downeyca.org/TitleVI

ATTACHMENT B

7 City of Downey Transit Services Title VI Program • May 2025

Notice of Civil Rights Posting in Transit Center (a Spanish version will also be posted) Actual Size – 8½ x 11

ATTACHMENT B

8 City of Downey Transit Services Title VI Program • May 2025

Notice for Posting in Dial-A-Ride Vehicles
Actual Size: 5.4 x 6.5

ATTACHMENT B

9 City of Downey Transit Services Title VI Program • May 2025

Notice for Downey LINK Fixed-Route Vehicles
Actual Size: 5.3” x 9.8”

ATTACHMENT B

10 City of Downey Transit Services Title VI Program • May 2025

ATTACHMENT 2

≡ CITY-WIDE TITLE VI LAP EXCERPT:

COMPLAINT PROCESS ≡

ATTACHMENT B

11 City of Downey Transit Services Title VI Program • May 2025

Excerpt from City-wide Language Access Plan May 2025

Page 4 ends

The City of Downey takes allegations of discrimination of any kind very seriously. Three specific categories of discrimination fall under Federal Title VI 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 VI complaints filed against the City and to make these procedures for filing a complaint available to the general public.

1. City of Downey Title VI Complaint Procedures
• 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 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 complaint procedures will be available in English, Spanish and Korean. • Complaint Investigation Process

2. Per the FHWA Guidance Memorandum, Processing of Title VI Complaints, dated June 13, 2018, all Title VI complaints received by a sub-recipient (the City of Downey) will be forwarded to the State DOT, Caltrans (email to: [email protected]) to be submitted to FHWA Division Office within one business day of receipt.

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, 1200 New Jersey Avenue, SE, 8th Floor E81- 105, Washington, DC 20590 and email to: [email protected], [email protected]).

The FHWA/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 VI complaint against a sub-recipient can be investigated by a Caltrans, HCR may delegate the task of investigating the complaint to Caltrans. If Caltrans’ Office of Business & Economic Opportunity (OBEO) is delegated the responsibility of performing an investigation, OBEO has 90 days to investigate the

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12 City of Downey Transit Services Title VI Program • May 2025

complaint. If additional time is needed, OBEO will call the Complainant and inform them.

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 to 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 additional information within ten business days, OBEO with consult with HCR regarding the disposition of the complaint. Disposition of Title VI complaint will be undertaken by HCR, through either (1) informal resolution or (2) issuance of a Letter of Finding of compliance or noncompliance with Title VI. A copy of the Letter of Finding will be sent 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 (HCR). All complaints filed under Title VI against State DOT’s are investigated by HCR. • 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 Transportation Commission, Attention: Title VI Manager, 1120 N Street, MS 52 Sacramento, California 95814. (916) 324- 8379, TTY 711, [email protected] • Title Vi And Other Discrimination Complaint Form -
https://catc.ca.gov/-/media/ctc-media/documents/programs/equity-public- engagement/title-vi-information/2021/april/ctc0001.pdf
FORMULARIO DE QUEJAS DE DISCRIMINACIÓN DEL TÍTULO VI Y OTRAS - https://forms.dot.ca.gov/v2Forms/servlet/FormRenderer?frmid=DOTOCR000 2SP
• U.S. Department of Transportation, Federal Highway Administration, Office of Civil Rights, 1200 New Jersey Avenue, SE, 8th Floor E81-105, Washington, DC 20590. (202)366-0693, [email protected]
• FHWA Complaints Alleging Violations for Title VI -
https://highways.dot.gov/civil-rights/title-vi-complaint • U.S. Department of Transportation, Federal Transit Administration- Office of Civil

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13 City of Downey Transit Services Title VI Program • May 2025

Rights, Attention: Complaint Team, 1200 New Jersey Avenue, SE, Washington, DC 20590, such a complaint must be filed within 180 calendar days of the date of the alleged discrimination.
• U.S. Department of Housing and Urban Development, One Sansome Street, Suite 1200, San Francisco, CA 94104, (415) 489-6400
• U.S. Department of Justice, 950 Pennsylvania Avenue, NW, Washington, DC 20530- 0001. (202) 514-2000
• US Department of Homeland Security, Office for Civil Rights and Civil Liberties, Compliance Branch, Mail Stop #0190, 2707 Martin Luther King Jr Ave SE Washington, DC 20528-0190. (866) 644–8360, Toll Free TTY: (866)644–8361, [email protected].

2. Ensuring Easy Access to Complaint Form and Procedures The City has developed a Title VI Complaint Form to document all complaints received by City and/or contractor staff (Attachment #2). 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.

3. Tracking and Recording Title VI Investigations, Complaints, and Lawsuits.

The City will maintain a list of all Title VI and of other nondiscrimination statues investigations, complaints, or lawsuits that pertain to allegations of discrimination 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 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.

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.

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14 City of Downey Transit Services Title VI Program • May 2025

ATTACHMENT 3

≡ TITLE VI COMPLAINT FORM ≡

ATTACHMENT B

15 City of Downey Transit Services Title VI Program • May 2025

Complaint form is available in English, Spanish and Korean either online, at the Transit Center, from City Hall or (upon request) by mail or email.

ATTACHMENT B

16 City of Downey Transit Services Title VI Program • May 2025

ATTACHMENT B

17 City of Downey Transit Services Title VI Program • May 2025

ATTACHMENT 4

≡ LIST OF TRANSIT-RELATED

TITLE VI INVESTIGATIONS,
COMPLAINTS AND LAWSUITS ≡

ATTACHMENT B

18 City of Downey Transit Services Title VI Program • May 2025

City of Downey
List of Transit-Related Title VI Investigations, Complaints and Lawsuits

As of May 2025, no complaints or lawsuits have been filed against the City of Downey Transit Services.

Complaints
Date
Complaint
Received
Type of Alleged
Discrimination
Name of Complainant Status Action Taken

Investigations
Date
Investigation
Commenced
Type of Alleged
Discrimination
Name of Target of
Alleged Discrimination
Status Resolution/Action Taken

Lawsuits
Date Lawsuit
Filed
Type of Alleged
Discrimination
Name of Person who
Filed Suit
Status Resolution

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19 City of Downey Transit Services Title VI Program • May 2025

ATTACHMENT 5

≡ PUBLIC PARTICIPATION PLAN ≡

ATTACHMENT B

20 City of Downey Transit Services Title VI Program • May 2025

CITY OF DOWNEY

PUBLIC PARTICIPATION PLAN
May 2025

Introduction
Downey Transit Services’ Public Participation Plan has been designed to help ensure that no one is prevented from participating in key issues in Downey’s transportation 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.

Public Outreach Activities
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, The Orbit community guide book, information tables, workshops and at local events. The following reflects the outreach that has been undertaken.

Flyers, Brochures and Mailings
Brochures for both Downey LINK (English and Spanish) and Dial-A-Ride (English and Spanish) are distributed at various sites throughout the City including libraries, 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 and available on the City’s website.

In addition, bi-annual mailings will be sent to community organizations that directly serve LEP, low income, and senior populations in Downey. These organizations will be asked to work 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 in languages other than English (including Spanish, Korean, Arabic, Armenian, Greek and Indonesian),
− Church programs that have special programs for the deaf and seniors, − Medical programs including free/low cost clinics,
− Senior residences, and
− Other programs that serve low-income residents.

Public Information Meetings
The City will conduct 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 as local 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

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21 City of Downey Transit Services Title VI Program • May 2025

transit programs and in potential identification of LEP populations that may be in need of assistance.

These workshops will be held in buildings that meet Americans with Disability Act requirements 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 activities include functions where a broad cross-section of the community can access available transit information, including schedules, brochures and flyers.

Substantial Service Changes
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 on proposed changes during said period and during the scheduled public hearing with the City 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 to any 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 target audience is expected to include LEP individuals, the meeting notices, flyers, and agendas 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.

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22 City of Downey Transit Services Title VI Program • May 2025

Assurances
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 will notify the public of protections against discrimination afforded them by Title VI Regulations 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.

Availability of Title VI Plans and Procedures
The City’s Title VI Plan and Procedures, as well as the Language Assistance Plan, are available on 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 to:

City Manager’s Office
City Hall – 3rd Floor
11111 Brookshire Avenue
Downey, CA 90241
(562) 299-6619

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23 City of Downey Transit Services Title VI Program • May 2025

ATTACHMENT 6

≡ LANGUAGE ASSISTANCE PLAN ≡

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24 City of Downey Transit Services Title VI Program • May 2025

CITY OF DOWNEY TRANSIT SERVICES

TITLE VI LANGUAGE ASSISTANCE PLAN
May 2025

Introduction
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 4702.1B, 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.

Background
The City of Downey’s Transit Service staff oversee Downey LINK and Dial-A- Ride; operations for both are contracted to MV Transportation. The Downey City Council is the policymaking 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 or proportion of LEP persons in the service area who may be served or are 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 of Downey transportation programs, activities, or services.

3. The nature and importance of programs, activities or services provided by the City of Downey transportation services to the LEP population.

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25 City of Downey Transit Services Title VI Program • May 2025

4. Resources available to the City of Downey Transit Services staff and overall cost to provide LEP assistance.

Summary: Four-Factor Analysis

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 City of Downey.

City of Downey staff reviewed ACS data from the 2023 United States Census Bureau and determined that 24% (25,057) of the City's population has limited English proficiency; that is, they speak English "less than very well." Of this LEP group, 87% (21,724) are Spanish speakers and 5.3% (1,322) 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.

For the languages that fall below the 1,000 person threshold, the City will not be including them 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 that are offered by the City. In the Transit division’s recent survey, contract and City transit staff report frequently interacting with LEP Spanish-speakers.

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 Downey LINK review, it was determined that over half of the Downey LINK riders are school- age children (12-18 years of age). For adult riders, many use Downey LINK to connect to other transportation providers for their work commute. In a review of 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.

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26 City of Downey Transit Services Title VI Program • May 2025

Factor 4: The resources available to City of Downey’s Transit Services staff and overall cost to 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, MV Transportation (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 a bilingual interpreter at public 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 or religious services. This seems to indicate 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 $3.95/minute 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 on the four-factor analysis, the City of Downey developed its Language Assistance Plan as outlined in the following section.

Language Assistance Plan

Identification of LEP Population
Downey Transit Services has developed several possible ways to assist in identifying LEP populations within the City, including:

1. Examine records to see if requests for language assistance have been received in the 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. MAOF senior and childcare services, county housing offices, and free

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27 City of Downey Transit Services Title VI Program • May 2025

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 to 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 disseminate bilingual transit information and announcements, and to notify the LEP population of 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. • 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

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28 City of Downey Transit Services Title VI Program • May 2025

provide translation services for individuals wishing to comment. City will also make every effort to have Korean translators available if requested. • Annual discussion/survey of drivers and other frontline staff, e.g. dispatchers and Dial-A- Ride schedulers, on their experience concerning any contacts with LEP persons 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 website www.downeyca.org/titleVI .

Safe Harbor Provision
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 by the City of Downey’s transportation department falls primarily within the Spanish-speaking community. As a result, all vital documents are translated into Spanish and the contract provider is required within their contract to be able to serve LEP Spanish-speaking clients.

Monitoring and Updating the Language Assistance Plan
The City of Downey will update the Language Assistance Plan as required by US DOT or when it is clear that higher concentrations of LEP individuals are present in the City's transit service area. Updates to the Language Assistance Plan will consider:
• How the needs of LEP persons have been addressed;
• The current LEP population in the service area;
• Determination as to whether the need for translation services has changed; and, • Whether complaints have been received concerning the City's failure to meet the needs of LEP individuals.

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29 City of Downey Transit Services Title VI Program • May 2025

ATTACHMENT 7

≡ SYSTEM-WIDE FIXED ROUTE
STANDARDS AND POLICIES ≡

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30 City of Downey Transit Services Title VI Program • May 2025

CITY OF DOWNEY
SYSTEM-WIDE SERVICE STANDARDS AND POLICIES FIXED-ROUTE SYSTEM – Downey LINK

Background
Downey LINK operates Monday through Friday from 6:30am to 6:30pm. Downey LINK does not operate on the following holidays: New Year’s Day, Memorial Day, Independence Day, Labor Day, Thanksgiving Day, Christmas Eve and Christmas Day.

To accommodate higher demand, Downey LINK operates additional vehicles (referred to as “Tripper Service”) at selected times and stops.

Downey LINK is currently operated by MV Transportation.

Service Standards

Vehicle Load for Downey LINK
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.

Vehicle Headway for Downey LINK
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.

On-Time Performance
Among the most important service standard for customers is on-time performance or adherence to the published schedules.

Definition of “On Time” Performance. The City considers any run that is between 0-5 minutes after the scheduled departure time to be “on time.”

Early Departure. No bus shall depart a designated time point early.

Schedule Reliability. The contract with MV Transportation identifies the acceptable on-time performance as 90% of bus departures.

Service Availability
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/C Line and Metro buses).

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The four routes total 106 stops, some of which are used by more than one line. The average distance between stops is approximately ½ mile. 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 ½ mile 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 Green/C line 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.

Service Policies

Distribution of Transit Amenities for Each Mode
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 LINK fixed-route service.

Seating and Bus Shelters. 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 standards and 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 and comments received during public input process are considered in these determinations. All seating and shelters are installed in a manner that promotes safety, comfort and convenience.

Provision of Printed Signs, System Maps and Schedules. This information is distributed to the 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
Downey LINK vehicles are assigned each day at random to a route. The fleet of seven Downey LINK buses are all the same in age, size, and capacity.

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Downey City CouncilMay 27, 2025

Downey City Council
May 27, 2025