ITEM 4. 10
CITY MANAGER' S REPORT
OCTOBER 13, 2025 CITY COUNCIL REGULAR MEETING
ITEM: APPROVE TITLE VI OF THE CIVIL RIGHTS ACT OF
1964 IMPLEMENTATION PLAN FOR THE CITY OF
LATH RO P
RECOMMENDATION: Adopt Resolution to Approve a Title VI Non - Discrimination Policy Implementation Plan in
Compliance with the Civil Rights Act of 1964 for the
City of Lathrop
SUMMARY:
Compliance with Title VI of the Civil Rights Act of 1964 is a requirement for the City of Lathrop to receive federal funding for transportation projects. To maintain its eligibility for financial assistance, the City must adopt the attached resolution approving the Title VI Implementation Plan and complete a Title VI Program Assessment Online Form by December 2025. The Title VI Program outlines policies and procedures to ensure transportation projects do not discriminate against, or place undue burdens on, protected classes.
BACKGROUND:
The City of Lathrop receives federal highway funds for transportation projects. To maintain eligibility for these funds, the City must adopt the attached resolution approving the Title VI Implementation Plan and complete the Title VI Program Assessment Online Form by December 2025.
Staff have prepared the attached Title VI Implementation Plan using available online resources. The Plan includes the following Non -Discrimination Policy Statement:
The City of Lathrop certifies it is committed to ensuring compliance with Title VI of the Civil Rights Act of 1964 and other non- discriminatory authorities, such that no person shall be excluded from participation in or be denied the benefits of any program or activity conducted by the City of Lathrop on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law.
Further, no person shall be subjected to discrimination under any program or activity conducted by the City of Lathrop, on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law.
In accordance with Federal Highway Administration ( FHWA) and Caltrans guidelines, the Plan also includes sections on Non -Discriminatory Legislation, Organization Structure, Complaint Procedure, Title VI Outreach and Resources, Data Collection
CITY MANAGER' S REPORT
OCTOBER 13, 2025 CITY COUNCIL REGULAR MEETING
APPROVE TITLE VI PROGRAM FOR THE CITY OF LATHROP
PAGE 2
and Analysis, Contract Documents and Agreements, Training, Annual Work Plan, and an Appendix with a Limited English Proficiency Plan, Notice to the Pubic, Complaint Form and assurances from the US Department of Transportation.
RECOMMENDATION:
Compliance with Title VI of the Civil Rights Act of 1964 is a requirement for the City of Lathrop to receive federal funding for transportation projects. Staff recommend that Council adopt the attached resolution approving the Title VI Implementation Plan for the City of Lathrop.
FISCAL IMPACT:
There are no immediate costs to the City associated with this action, aside from staff time required to implement the Title VI Plan. Compliance with Title VI of the Civil Rights Act of 1964 is necessary to maintain eligibility for federal transportation funding. The estimated staff time needed for ongoing implementation will be incorporated into future operating budget plans.
ATTACHMENTS:
A. Resolution to Approve a Title VI Program for the City of Lathrop B. City of Lathrop Title VI Program, October 2025
CITY MANAGER' S REPORT
OCTOBER 13, 2025 CITY COUNCIL REGULAR MEETING
APPROVE TITLE VI PROGRAM FOR THE CITY OF LATHROP
APPROVALS:
45. 0-
Greg C3ybson Date
Senior Civil Engineer
Brad ylor
City ngineer
Juliana Bur
Human Resources Director
Date
6146407 -c --
9/ 7} i/vac
1/0/ Zorc
Date
Michael King Date
Assistant City Manager
1.- I1- ZozS
Salvador Navarrete Date
City Attorney
Step en J. Salvatore Date
City Manager
PAGE 3
RESOLUTION NO. 25 -
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LATHROP TO
APPROVE A TITLE VI NON- DISCRIMINATION POLICY IMPLEMENTATION PLAN IN COMPLIANCE WITH THE CIVIL RIGHTS ACT OF 1964 FOR THE CITY
OF LATHROP
WHEREAS, compliance with Title VI of the Civil Rights Act of 1964 is a requirement for the City of Lathrop to receive federal funding for transportation projects; and
WHEREAS, in order to maintain its eligibility for federal financial assistance, the City must adopt the attached resolution to approving the Title VI Implementation Plan and complete a Title VI Program Assessment Online Form by December 2025; and
WHEREAS, the Title VI Program outlines policies and procedures to ensure transportation projects do not discriminate or place undue burdens on protected classes; and
WHEREAS, staff have prepared a Title VI Implementation Plan for Lathrop using online resources; and
WHEREAS, there are no immediate costs to the City associated with this action aside from staff time for implementation of the Title VI Plan.
NOW THEREFORE, BE IT RESOLVED, the City Council of the City of Lathrop does hereby approve the Title VI Implementation Plan that accompanied the staff report for this resolution.
The foregoing resolution was passed and adopted this 13th day of October 2025, by the following vote of the City Council, to wit:
AYES:
NOES:
ABSENT:
ABSTAIN:
Paul Akinjo, Mayor
ATTEST: APPROVED AS TO FORM:
Teresa Vargas, City Clerk Salvador Navarrete, City Attorney Attachment B
CITY OF LATHROP
TITLE VI IMPLEMENTATION PLAN
Adopted October 13, 2025
Table of Contents
Non -Discrimination Policy Statement 1
Non -Discriminatory Legislation 2
Organization Structure 3
Title VI Coordinator 3
Assistant Title VI Coordinator 3
Title VI Specialist 3
Title VI Liaison 4
Title VI Organization Chart 4
Complaint Procedure 5
Complaints Processed Under the Federal Highway Administration 5 Ca! trans OCR Investigation Process 6
Title VI Outreach and Resources 7
Limited English Proficiency 7
Title VI Information Dissemination 7
Environmental Justice 8
Data Collection and Analysis 8
Contract Documents and Agreements 8
Training 9
Annual Work Plan 9
Appendix 10
A. Limited English Proficiency Plan 10
B. Notice to Public 13
C. Complaint Form 14
D. US DOT Title VI Assurances A -E 16
Non -Discrimination Policy Statement
The City of Lathrop Public Works Department is committed to ensuring compliance with Title VI of the Civil Rights Act of 1964 and other non- discriminatory authorities, such that no person shall be excluded from participation in or be denied the benefits of any program or activity conducted by the City of Lathrop Public Works Department on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law.
Further, no person shall be subjected to discrimination under any program or activity conducted by the City of Lathrop Public Works Department, on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law.
Title VI compliance is a condition of receipt of federal funds. The Title VI Coordinator is authorized to ensure compliance with this policy, Title VI of the Civil Rights Act of 1964, 42 U. S. C § 2000d and related statutes, and the requirements of 23 Code of Federal Regulation ( CFR) pt. 200 and 49 CFR pt. 21.
Michael King Date
Assistant City Manager, City of Lathrop
Title VI Implementation Plan
City of Lathrop
1 Non -Discriminatory Legislation
Title VI of the Civil Rights Act of 1964 — Provides that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination, under any program or activity receiving Federal financial assistance ( as implemented through 23 CFR 200. 9 and 49 CFR 21).
Section 162( a) of the Federal -Aid Highway Act of 1973 ( Section 324, Title 23 U. S. C.) — Prohibits discrimination on the basis of sex by recipients and sub -recipients of Federal financial assistance.
Section 504 of the Rehabilitation Act of 1973 — Prohibits discrimination on the basis of disability by recipients and sub -recipients of Federal financial assistance.
The Age Discrimination Act of 1975 ( Section 6101-107, Title 42 U. S. C.) — Prohibits discrimination on the basis of age by recipients and sub -recipients or Federal financial assistance.
The Civil Rights Restoration Act of 1987 ( Public Law 200- 209) — Clarifies that the original intent of Congress in Title VI of the Civil Rights Act of 1964, Title IX of the Educational Amendments of 1972, the Age Discrimination Act of 1975, and Section 504 of the Rehabilitation Act of 1973 was to apply the non- discrimination statutes to all programs and activities of Federal - aid recipients, sub -recipients, contractors and vendors, whether all such programs are federally assisted or not.
Executive Order 12898 ( issued February 11, 1994) — Addresses Environmental Justice regarding minority and low- income populations and requires agencies to develop strategies to address disproportionately high and adverse human health or environmental effects of their programs on minority and low- income populations; promote nondiscrimination in federal programs substantially affecting human health and the environment; and provide minority and low- income communities access to public information and an opportunity for public participation in matters relating to human health or the environment.
Executive Order 13166 ( issued August 16, 2000) — Addresses improved access to services for persons with limited English proficiency. Agencies are directed to evaluate services provided and implement a system that ensures that Limited English Proficiency ( LEP) persons are able to meaningfully access the services provided consistent with, and without unduly burdening, the fundamental mission of the local agency. Agencies are directed to ensure that recipients of federal financial assistance provide meaningful access to program, services and information to their LEP applicants and beneficiaries free of charge.
Title VI Implementation Plan
City of Lathrop
2 Organization, Staffing and Structure
The City of Lathrop' s Title VI program is a multi -tiered program in which multiple roles work toward the ultimate goal of assuring full compliance with the provisions of Title VI of the Civil Rights Act of 1964 and related statutes. The City has assigned the roles of Title VI Coordinator, Assistant Title VI Coordinator, Title VI Specialist and Title VI Liaison to designated individuals in the Public Works and Human Resources Departments.. Their specific roles and responsibilities are as follows:
Title VI Coordinator ( Assistant City Manager/ City Engineer):
Maintains a direct line of communication with City Manager, City Council, City Leadership positions
Assistant Title VI Coordinator ( HR):
Develops, Plans and Coordinates Training for managers, supervisions and staff with frequent public contact.
Collects Demographic Data from US Censor
Have a readily available list of certified translators and provide list to staff with frequent public contact
Title VI Specialist ( Public Works: Assistant Engineer):
Prepares and coordinates Title VI plan and annual report submissions Develops Title VI information for dissemination to the public Ensures Title VI Assurances have been incorporated into all Federal -aid Contracts and Agreements
Prepares annual reports
Processes Complaints after received ( no more than 180days). Should go to Legal and Risk Management as soon as a complaint is received
Title VI Liaison ( HR risk management; Public Works: Assistant Engineer/ Management Analyst/ Project Manager):
Works directly with contractors, public, counter
Reports complaints through complaint procedures
Key Responsibilities ( assigned to entire group as a whole):
Program Implementation:
Leading the development and implementation of the organization' sTitle VI program and procedures.
Monitoring and Compliance:
Monitoring all federal -aid programs, activities, and services for compliance with Title VI requirements and preparing annual reports.
Title VI Implementation Plan
City of Lathrop
3 Complaint Resolution:
Receiving, investigating, and resolving formal and informal complaints of discrimination.
Data Collection:
Collecting and analyzing demographic data of participants in federally funded programs and services.
Guidance and Training:
Providing technical assistance, guidance, and training to staff, regional offices, and sub -recipients on Title VI requirements.
Public Outreach:
Ensuring public information is available in other languages when needed and participating in public involvement activities to ensure adequate representation of all groups.
Risk Assessment:
Conducting periodic Title VI audits and risk assessments to identify and address potential deficiencies or conflicts.
Reporting:
Preparing and submitting annual reports on Title VI accomplishments, goals, and any identified issues to the agency administrator and relevant federal bodies.
Program Implementation:
Leading the development and implementation of the organization' sTitle VI program and procedures.
Monitoring and Compliance:
Monitoring all federal -aid programs, activities, and services for compliance with Title VI requirements and preparing annual reports.
Complaint Resolution:
Receiving, investigating, and resolving formal and informal complaints of discrimination.
Data Collection:
Collecting and analyzing demographic data of participants in federally funded programs and services.
Guidance and Training:
Title VI Implementation Plan
City of Lathrop
4 Providing technical assistance, guidance, and training to staff, regional offices, and sub -recipients on Title VI requirements.
Public Outreach:
Ensuring public information is available in other languages when needed and participating in public involvement activities to ensure adequate representation of all groups.
Risk Assessment:
Conducting periodic Title VI audits and risk assessments to identify and address potential deficiencies or conflicts.
Reporting:
Preparing and submitting annual reports on Title VI accomplishments, goals, and any identified issues to the agency administrator and relevant federal bodies.
Organizational Chart
Title VI
Coordinator
Michael King, Brad Taylor
Title VI
Liaison
Carlos Carillo
Title VI
S•- •.Ii t
Angel Abarca
Title VI
Liaison
Leisser Mazarigos
Title VI Implementation Plan
City of Lathrop
5 Asst. Title VI
Coordinator
Juliana Burns
Title VI
Liaison
Angel Abarca
Complaint Procedure
The City of Lathrop Public Works Department is committed to ensuring compliance with Title VI of the Civil Rights Act of 1964 and other non- discriminatory authorities, such that no person shall be excluded from participation in or be denied the benefits of any program or activity conducted by the City of Lathrop Public Works Department on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law.
Any person that believes they have been discriminated against on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law by the City of Lathrop' sPublic Works Department, its contractors, consultants or any other party that acts on behalf of the Public Works Department may file a Title VI complaint by completing and submitting the City' s Title VI Complaint Form ( Appendix C), which can be found displayed in the City Hall lobby, and online at « Insert Link» .
The City' sTitle VI Specialist processes complaints received no more than 180 days after the alleged incident. The Title VI Specialist will only process complaints that are complete, which include at a minimum, the following:
Complainant' scontact information
Date of alleged act of discrimination
Details of the alleged discrimination
The complainant' ssignature
Once the Title VI complaint is received, the Title VI Specialist will forward the complaint to Caltrans, to be submitted to the FHWA Division Office. The Title VI Specialist will also begin processing the complaint by entering said complaint into the City' s Title VI Discrimination Complaint Log, and conducting an internal investigation. Once a finding has been determined/ received, the City' sTitle VI Specialist will provide said finding to the complainant within ten business days via letter and/ or email.
Complaints Processed Under the Federal Hiahwav Administration Title VI complaints filed with Caltrans in which Caltrans is named as the Respondent will be forwarded to the FHWA Division Office. The Complainant will receive an acknowledgement letter informing them that the complaint has been received and forwarded to the FHWA.
Per the FHWA Guidance Memorandum, Processing of Title VI Complaints, dated June 13, 2018, all Title VI complaints received by a sub -recipient (City of Lathrop) are to be forwarded to Caltrans to be submitted to FHWA Division Office. Complaints should be sent within one business day of receipt via email to Title. Vl@dot. ca. gov. If Headquarters Office of Civil Rights ( HCR) determines a Title VI complaint against a sub -recipient can Title VI Implementation Plan
City of Lathrop
6 be investigated by Caltrans, HCR may delegate the task of investigating the complaint to Caltrans.
Ca trans OCR Investiaation Process
If OCR is delegated the responsibility of performing an investigation, OCR has 90 days to investigate the complaint. If additional time is needed, OCR will call the Complainant and inform them.
If more information is needed to resolve the case, the OCR 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, OCR can administratively close the case. A case can be administratively closed also if the complainant no longer wishes to pursue their case
OCR 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.
A person may also file a complaint directly with the FHWA and/ or Caltrans by the following contact information:
Federal Highway Administration
U. S. Department of Transportation
Office of Civil Rights
1200 New Jersey Avenue, SE
8th Floor E81- 104
Washington, DC 20590
California Department of Transportation
Office of Civil Rights
Attention: Title VI Program Branch
1823 14th Street, MS 79
Sacramento, CA 95811
Title. VIa. dot. ca. gov
Should a complaint be filed with the City of Lathrop Public Works Department and one with a federal or state agency simultaneously, the federal/ state complaint will supersede the City' scomplaint and the City' scomplaint procedures will be suspended pending the federal/ state agency' sfindings.
Title VI Implementation Plan
City of Lathrop
7 Title VI Outreach and Resources
Table 1: Languages Spoken by City of Lathrop Residents
Language Spoken
Group
Population
Group' s
Percentage
of
Population
Portion of
Group that
Speaks
English Very
Well
Portion of
Group That
Does Not
Speak English
Ver Well
English Only
Spanish
Other Indo- European
Lan. ua• es
Asian and Pacific Island
Lan• uages
Other Languages
Total Population Above 5 Years
5772
4384 14. 5 2360 ( 53. 8%) 2024 ( 46. 2%)
9 30189
19. 0 3994 ( 68. 9%)1778 ( 31. 1%)
66 6.%)
25215 (83. 5%) 4974 ( 16. 5%)
Source: US Census: American Community Survey 2019-023 5 -Year Estimate https:// data. census. gov/ table/ ACSST5Y2023. S 1601 ? q=Lathrop,+ CA+ Language Limited English Proficiency
A Limited English Proficiency ( LEP) person is a person that does not speak English as a primary language and has a limited ability to read, write, or comprehend English. Per Executive Order 13166, agencies which receive Federal funding must examine their Federally -funded services and develop and implement processes that will allow LEP persons to meaningfully access said services. Executive Order 13166 also requires that agencies receiving Federal funding must establish guidance for providing meaningful access to LEPs, prepare a plan to overcome language barriers in Federally -funded programs and activities, and ensure that stakeholders have adequate opportunity to provide input.
As shown in Table 1 above, 16. 5% of residents in the City of Lathrop are considered LEP persons, with the majority of those LEP persons primarily speaking Spanish ( 19% of the community), Other Indo- European Languages ( 12. 2% of the community), Asian and Pacific Island Languages ( 14. 5% of the community) and Other Languages ( 0.7% of the community). As outlined in the City' s LEP Plan ( Appendix A), the City has conducted an LEP Needs Assessment, using a Four Factor Analysis to identify need and provide access to the LEP community in compliance with Executive Order 13166.
Title VI Information Dissemination
In order to ensure that Title VI and related Civil Rights information is readily available to the public, the City will develop public notices consisting of posters, flyers, complaint forms and " I Speak" cards that are available in English, Spanish, and Punjabi. The languages selected for the informational materials were based upon language data provided from the US Census; see Table 1 above. Said flyers and posters will be placed in the City Hall lobby, in a highly visible and accessible location. The public notices will also be available for viewing on the City' swebsite, at « Insert Link».
Title VI Implementation Plan
City of Lathrop
8 Environmental Justice
In accordance with Executive Order 12898 ( Federal Actions to Address Environmental Justice in Minority Populations and Low -Income Populations), City Staff will identify and address the environmental effects of programs, policies, and activities on minority and low- income populations for Federally -funded projects. Staff will consider demographic data during project design and involve the public in the planning and development process to assess the environmental impacts of projects on the community. The public' sinput and demographic data analysis will enable staff to develop measures to mitigate any potential adverse effects on minority and low- income populations.
Data Collection and Analysis
Demographic and related data collected and used by City staff comes from governmental sources responsible for collecting and vetting the information for consistency and accuracy. These sources include, but are not limited to, the U. S. Bureau of Labor Statics, U. S. Census Bureau, U. S. Bureau of Economic Analysis, California Department of Finance, California Department of Labor, and the California Employment Development Department.
Additionally, staff may also collect project -specific demographic data utilizing data collection as appropriate through the public outreach process on Federally -funded projects. Such outreach that may give Staff the opportunity to collect demographic data may include door hangers, posters, emails, social media releases, press releases to local newspaper, public meetings, virtual meetings, and public comment through websites generated for projects.
Contract Documents and Agreements
The City' s Title VI Specialist will ensure that any Federally -funded project documents contain the necessary Title VI Assurances and other language. Such assurances include, but may not be limited to:
FHWA Form 1273 ( Title VI and other non- discriminatory requirements) o Required on all FHWA contracts and subcontracts valued greater than 10, 000
Title VI Assurances Appendix A -E
o Appendix A -E to be attached to Federal -Aid contracts Additionally, City staff will include the provisions indicated in the "Administering Agency - State Agreement for Federal -Aid Projects Master Agreement" in the Local Assistance Program Manual ( LAPM) in contracts and agreements, where applicable, between the City and contractors.
The City will continue to utilize the " Local Agency Construction Contract Administration Checklist" (Exhibit 15- A of the LAPM), which confirms that DBE and labor/ Equal Title VI Implementation Plan
City of Lathrop
9 Employment Opportunity ( EEO) compliance requirements are performed and documented in the project files. Exhibit 15- Aof the LAPM documents that the local agency will meet all the requirements prior to the award of a construction contract.
Lastly, the City will continue to utilize the " Resident Engineer' s Construction Contract
Administration Checklist" (Exhibit 15- B of the LAPM) on federal -aid projects. The checklist assists in administering federal -aid highway construction projects and provides a record that the EEO/ Wage Rate/ False Statements posters are being posted at specific locations that employee interviews will be conducted in accordance with the Labor Compliance/ EEO interview form, and that DBE requirements are met. City staff will continue to submit Exhibit 15- B, along with the Award Package shortly after award of the construction contract.
Training
The City of Lathrop Human Resources Department will provide Title VI and related statute training to Public Works managers, supervisors, and staff with frequent public contact in the administration of federal -aid programs. These trainings will occur at minimum every two years, and within six months of hiring a new employee. The trainings will be conducted by the Title VI Specialist, online through presentations, or through trainings hosted by Caltrans. Additionally, links to Caltrans, FHWA, and other applicable agency resources for Title VI and related statutes will be posted on the City' s website at « Insert
Link».
In particular, the following items will be covered in trainings:
Review of Yuba City' s Title VI Implementation Plan and other relevant documents Language assistance services and " I Speak Cards" offered for public use How to handle potential complaints
Where to seek assistance for Title VI questions and concerns Annual Work Plan
The City of Lathrop Public Works Department will annually establish and monitor program goals and accomplishments. The Title VI Specialist will ensure that employee training is conducted, language translation services continue to be available, public participation is optimal, and appropriate Title VI signage is posted. This also includes updating community statistics and corresponding with state and federal agencies as necessary.
Title VI Implementation Plan
City of Lathrop
10 Appendix A
LIMITED ENGLISH PROFICIENCY PLAN
Backaround
Executive Order 13166, " Improving Access to Services for Persons with Limited English Proficiency" requires that Federal agencies work to ensure that the recipients of Federal financial assistance provide meaningful access to their Limited English Proficiency ( LEP) applicants and beneficiaries.
As such, local agencies are required to ensure that Federally - funded programs and activities normally provided in English are accessible to LEP Persons. Each local agency shall perform an annual assessment to determine if modifications are needed to their programs and activities to ensure meaningful access by LEP persons. The assessment which is referred to as a " Four - Factor" analysis is based on the following factors:
1. The number or proportion of LEP persons eligible to be served or likely to be encountered.
2. The frequency of LEP contacts.
3. The nature and importance of the programs, services, or activities provided by the City of Lathrop.
4. The resources available for LEP persons
The City of Lathrop is approximately 40 miles north of Sacramento and has a population of approximately 62, 000 (US Census: American Community Survey 2015-019 5 -Year Estimate).
Of the 62, 000 residents, approximately 20. 1% of the residents are Spanish speaking, and 18. 3% of the residents are Other Indo- European Language speaking. Based on the large Sikh population in Yuba City ( nearly 12, 000) it is safe to assume that the primary language of the Other IndoEuropean Languages listed in the Census is Punjabi.
Four -Factor Analysis
1. The number or proportion of LEP persons eligible to be served or likely to be encountered.
As shown in Table 1 below, the City of Lathrop has approximately 30, 189 residents. 16. 5% of residents in the City of Lathrop are considered LEP persons, with the majority of those LEP persons primarily speaking Spanish ( 19% of the community), Other Indo- European Languages
12. 2% of the community), Asian and Pacific Island Languages ( 14. 5% of the community) and Other Languages ( 0.7% of the community).
Title VI Implementation Plan
City of Lathrop
11 Table 1: Languages Spoken by City of Lathrop Residents Language Spoken
Group
Population
Group' s
Percentage
of
Population
Portion of
Group that
Speaks
English Very
Well
Portion of
Group That
Does Not
Speak English
Ve Well
English Only
Spanish
Other Indo- European
Lan. ua• es
Asian and Pacific Island
Lan• uages
Other Languages
Total Population Above 5 Years
5772 19. 0 3994 ( 68. 9%)1778 ( 31. 1%)
4384 14. 5 2360 (53. 8%)2024 ( 46. 2%)
0. " ( 16i
30189 X 25215 ( 83. 5%) 4974 ( 16. 5%)
Source: US Census: American Community Survey 2019-023 5 -Year Estimate https:// data. census. gov/ table/ ACSST5Y2023. S1601 ?q=Lathrop,+ CA+ Language
2. The frequency of LEP contacts.
No data has been collected regarding frequency of contact with LEP persons at the City. Most interactions with LEP persons occur at the City' s Finance Department due to residents paying utility bills. Based on observation from Finance Department front -counter staff, the frequency for translation from Spanish to English is on average once per day. The frequency for translation from Punjabi to English is on average once per week. Currently the City' s Human Resources
Department retains a list which lists all City staff which are certified translators for various languages. If front counter staff that speak either Spanish or Punjabi are not available, City staff will reach out to a certified translator from the list.
Public Works staff does not regularly receive requests for translation through Federally funded programs/ projects, though the outreach components of said programs/ projects do typically have multi- lingual resources. Further, if translation services are needed, staff will provide said translation in a timely manner.
3. The nature and importance of programs, services, or activities provided by the City of Lathrop.
From observation provided by Public Works staff, it is rare that translation services are requested for programs, services, or activities which are Federally -funded. As stated above, the front counter Staff with the City' s Finance Department are the ones who most frequently encounter LEP persons requesting and/ or needing translation services.
Though Public Works Staff has received very few requests for translation services on Federally - funded projects, programs and services, Staff is keenly aware that almost twenty percent of the City' s residents are LEPs and therefore it is highly likely that LEPs will be stakeholder in any of the said projects, programs and services. As such, when Staff has encountered the need for translation services, Staff has provided the services readily.
Title VI Implementation Plan
City of Lathrop
12 4. The Resources Available for LEP persons.
After a review of the City' scurrently available resources for LEP persons, the City has determined that the current available resources are lacking and inconsistent. The City will remedy the lack of resources, through the action plan listed in the next section.
Action Plan
In order to ensure compliance with Title VI, and Executive Order 13166 the following publications and services will be made available for LEP person use:
Non -Discrimination Policy Statement
o Statement shall be printed in English, Spanish and Punjabi. Said statement will be posted in the City HaII lobby in a highly visible location.
Title VI Rights Poster
o Posters shall be printed in English, Spanish and Punjabi. Said posters will be posted in the City Hall lobby in a highly visible location, and additional copies will be available for the public to review and take.
Title VI Complaint Form
o Complaint forms shall be printed in English, Spanish and Punjabi. Said forms will be in the City Hall lobby in a highly visible location.
I Speak Cards
o I Speak Cards will be produced to easily identify translation services needed for English, Spanish, and Punjabi. Said cards will be placed at all public counters and with the other Title VI information.
Title VI Webpage on City' sWebsite
o All of the City' s Title VI resources will be posted on the City' s website at the
following link: « Insert Link».
Future Planning and Projects
o Public Works will ensure that all future projects and planning documents that are federally -funded utilize outreach methods that are compliant with Title VI and other related non- discriminatory assurances.
o Additionally, the City will ensure that outreach materials are available in English, Spanish, and Punjabi, and that translators are readily available as necessary for any LEP Persons that would like to contribute or participate.
Lastly, the Title VI Specialist will request an updated list of certified translators from the Human Resources Department every six months, and distribute said list to those who are likely to encounter LEP persons, such that a translator can be contacted the moment one is needed.
To ensure continuous compliance, the City will review the Title VI Implementation Plan and Limited English Proficiency Plan regularly, but at a minimum, as new data from the US Census becomes available. As new regulations are created, the City will act promptly to update the existing plans and relevant resources.
Title VI Implementation Plan
City of Lathrop
13 Appendix B
YOUR RIGHTS AGAINST DISCRIMINATION UNDER
TITLE VI OF THE CIVIL RIGHTS ACT OF 1964 AND
RELATED NON- DISCRIMINATORY AUTHORITIES
Title VI of the Civil Rights Act of 1964 provides that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance.
The following additional authorities provide protection against discrimination on the basis of sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law:
Section 162( a) of the Federal - Aid Highway Act of 1973 (Section 324, Title 23 U. S. C.) Section 504 of the Rehabilitation Act of 1973
The Age Discrimination Act of 1975 (Section 6101-107, Title 42 U. S. C.) The Civil Rights Restoration Act of 1987 ( Public Law 200-9) Executive Order 12898 ( issued February 11, 1994)
Executive Order 13166 ( issued August 16, 2000)
Any person who believes that they have been discriminated against may file a written complaint with the City of Lathrop Public Works Department, within 180 days of the alleged discrimination. Additional information and Title VI Complaint Forms can be obtained on the City of Lathrop' s website, at the following location:
www. yubacity. net/ TitleVl . Title VI Complaint Forms can also be obtained from the Public Works Department at City Hall.
To file a Title VI discrimination complaint, please use the following contact information:
City of Lathrop Public Works
390 Towne Centre Drive
Lathrop, CA 95330
209) 941- 7430
website_ pwk@ci. lathrop. ca. us
Title VI Implementation Plan
City of Lathrop
14 Appendix C
TITLE VI COMPLAINT FORM
Title VI of the 1964 Civil Rights Act requires that " No person in the United States shall on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance." If you wish to submit a Title VI complaint to the City of Lathrop Public Works Department, please complete the below information and submit this form to:
City of Lathrop Public Works
390 Towne Centre Drive
Lathrop, CA 95330
209) 941- 7430
website_ pwk@ci. lathrop. ca. us
Name:
Address:
City: State: Zip Code:
CeII: Home:
Name, title, and description of person( s) who allegedly discriminated against you:
Check the box( es) for the type( s) of discrimination that was experienced:
Race
Color
National Origin
Other ( Please Describe):
Sex
Age
Disability
Religion
Sexual Orientation
Gender Identity
Date( s) that alleged event( s) took place:
Location( s) where the alleged event( s) took place:
Title VI Implementation Plan
City of Lathrop
15 Is the alleged discrimination still ongoing?:
In your own words, please describe the alleged discrimination, explain what happened, and who you believe is responsible:
Please list any person( s) we may contact for additional information to provide further information for your complaint:
Have you filed this complaint with any other federal agency, state agency, federal court, or state court?:
If yes, please check all that apply:
Federal Agency
State Agency
Federal Court
State Court
Please provide the name, phone number, and email of the contact persons at the agency/ court where the complaint was filed, below:
Please sign and date this form on the lines provided below. If any additional space is needed to provide information about this complaint, please attach the additional information to this form.
Signature: Date:
Title VI Implementation Plan
City of Lathrop
16 Appendix D
US DOT Title VI Assurances A -E
APPEND XA
During the performance of this contract, the contractor, for itself, its assignees, and successors in interest hereinafter referred to as the "contractor") agrees as follows:
1. Compliance with Regulations: The contractor ( hereinafter includes consultants) will comply with the Acts and the Regulations relative to Nondiscrimination in Federally -assisted programs of the U. S.
Department of Transportation, Federal Highway Administration, as they may be amended from time to time, which are herein incorporated by reference and made a part of this contract.
2. Non- discrimination: The contractor, with regard to the work performed by it during the contract, will not discriminate on the grounds of race, color, national origin, age, sex, or disability in the selection and retention of subcontractors, including procurements of materials and leases of equipment. The contractor will not participate directly or indirectly in the discrimination prohibited by the Acts and the Regulations, including employment practices when the contract covers any activity, project, or program set forth in Appendix B of 49 CFR Part 21.
3. Solicitation for Subcontracts, Including Procurements of Materials and Equipment: In all solicitations, either by competitive bidding, or negotiation made by the contractor for work to be performed under a subcontract, including procurements of materials, or leases of equipment, each potential subcontractor or supplier will be notified by the contractor of the contractor' sobligations under this contract and the Acts and the Regulations relative to Non- discrimination on the grounds of race, color, national origin, age, sex, or disability.
4. Information and Reports: The contractor will provide all information and reports required by the Acts, the Regulations, and directives issued pursuant thereto and will permit access to its books, records, accounts, other sources of information, and its facilities as may be determined by the Recipient or the FHWA to be pertinent to ascertain compliance with such Acts, Regulations, and instructions. Where any information required of a contractor is in the exclusive possession of another who fails or refuses to furnish the information, the contractor will so certify to the Recipient or the FHWA, as appropriate, and will set forth what efforts it has made to obtain the information.
5. Sanctions for Noncompliance: In the event of a contractor' s noncompliance with the Nondiscrimination provisions of this contract, the Recipient will impose such contract sanctions as it or the FHWA may determine to be appropriate, including, but not limited to:
1. withholding payments to the contractor under the contract until the contractor complies; and/ or
2. cancelling, terminating, or suspending a contract, in whole or in part.
6. Incorporation of Provisions: The contractor will include the provisions of paragraphs one through six in every subcontract, including procurements of materials and leases of equipment, unless exempt by the Acts, the Regulations and directives issued pursuant thereto. The contractor will take action with respect to any subcontract or procurement as the Recipient or the FHWA may direct as a means of enforcing such provisions including sanctions for noncompliance. Provided, that if the contractor becomes involved in, or threatened with litigation by a subcontractor, or supplier because of such direction, the contractor may request the Recipient to enter into any litigation to protect the interests of the Recipient. In addition, the contractor may request the United States to enter into the litigation to protect the interests of the United States.
Title VI Implementation Plan
City of Lathrop
17 APPENDIX B
CLAUSES FOR DEEDS TRANSFERRING UNITED STATES PROPERTY
The following clauses will be included in deeds effecting or recording the transfer of real property, structures, or improvements thereon, or granting interest therein from the United States pursuant to the provisions of Assurance 4:
NOW THEREFORE, the U. S. Department of Transportation as authorized by law and upon the condition that the California Department of Transportation will accept title to the lands and maintain the project constructed thereon in accordance with Title 23 U. S. C., the regulations for the administration of the preceding statute, and the policies and procedures prescribed by the FHWA of the U. S. Department of Transportation in accordance and in compliance with all requirements imposed by Title 49, Code of Federal Regulations, U. S. Department of Transportation, Subtitle A, Office of the Secretary, Part 21, Nondiscrimination in Federally - assisted programs of the U. S. Department of Transportation pertaining to and effectuating the provisions of Title VI of the Civil Rights Act of 1964 ( 78 Stat. 252; 42 U. S. C. § 2000d to 2000d- 4), does hereby remise, release, quitclaim and convey unto the California Department of Transportation all the right, title and interest of the U. S. Department of Transportation in and to said lands described in Exhibit A attached hereto and made a part hereof.
HABENDUM CLAUSE)
TO HAVE AND TO HOLD said lands and interests therein unto the California Department of Transportation and its successors forever, subject, however, to the covenants, conditions, restrictions and reservations herein contained as follows, which will remain in effect for the period during which the real property or structures are used for a purpose for which Federal financial assistance is extended or for another purpose involving the provision of similar services or benefits and will be binding on the California Department of Transportation, its successors and assigns.
The California Department of Transportation, in consideration of the conveyance of said lands and interest in lands, does hereby covenant and agree as a covenant running with the land for itself, its successors and assigns, that ( 1) no person will on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination with regard to any facility located wholly or in part on, over, or under such lands hereby conveyed [,] [ and]* (2) that the California Department of Transportation will use the lands and interests in lands and interest in lands so conveyed, in compliance with all requirements imposed by or pursuant to Title 49, Code of Federal Regulations, U. S. Department of Transportation, Subtitle A, Office of the Secretary, Part 21, Nondiscrimination in Federally - assisted programs of the U. S. Department of Transportation, Effectuation of Title VI of the Civil Rights Act of 1964, and as said Regulations and Acts may be amended[, and ( 3) that in the event of breach of any of the above - mentioned non- discrimination conditions, the Department will have a right to enter or re- enter said lands and facilities on said lands, and that above described land and facilities will thereon revert to and vest in and become the absolute property of the U. S. Department of Transportation and its assigns as such interest existed prior to this instruction].* Reverter clause and related language to be used only when it is determined that such a clause is necessary in order to make clear the purpose of Title VI.) Title VI Implementation Plan
City of Lathrop
18 APPENDIX C
CLAUSES FOR TRANSFER OF REAL PROPERTY ACQUIRED OR IMPROVED UNDER THE ACTIVITY,
FACILITY, OR PROGRAM
The following clauses will be included in deeds, licenses, leases, permits, or similar instruments entered into by the California Department of Transportation pursuant to the provisions of Assurance 7(a):
A. The ( grantee, lessee, permittee, etc. as appropriate) for himself/ herself, his/er heirs, personal representatives, successors in interest, and assigns, as a part of the consideration hereof, does hereby covenant and agree [ in the case of deeds and leases add " as a covenant running with the land"] that:
1. In the event facilities are constructed, maintained, or otherwise operated on the property described in this (deed, license, lease, permit, etc.) for a purpose for which a U. S. Department of Transportation activity, facility, or program is extended or for another purpose involving the provision of similar services or benefits, the ( grantee, licensee, lessee, permittee, etc.) will maintain and operate such facilities and services in compliance with all requirements imposed by the Acts and Regulations ( as may be amended) such that no person on the grounds of race, color, or national origin, will be excluded from participation in, denied the benefits of, or be otherwise subjected to discrimination in the use of said facilities.
B. With respect to licenses, leases, permits, etc., in the event of breach of any of the above Nondiscrimination covenants, the California Department of Transportation will have the right to terminate the lease, license, permit, etc.) and to enter, re- enter, and repossess said lands and facilities thereon, and hold the same as if the ( lease, license, permit, etc.) had never been made or issued." C. With respect to a deed, in the event of breach of any of the above Nondiscrimination covenants, the California Department of Transportation will have the right to enter or re- enter the lands and facilities thereon, and the above described lands and facilities will there upon revert to and vest in and become the absolute property of the California Department of Transportation and its assigns.* Reverter clause and related language to be used only when it is determined that such a clause is necessary to make clear the purpose of Title VI.)
Title VI Implementation Plan
City of Lathrop
19 APPENDIX D
CLAUSES FOR CONSTRUCTION/ USE. ACCSS TO REAL PROPERTY ACQUIRED UNDER THE
ACTIVITY, FACILITY OR PROGRAM
The following clauses will be included in deeds, licenses, permits, or similar instruments/ agreements entered into by the California Department of Transportation pursuant to the provisions of Assurance 7(b):
A. The (grantee, licensee, permittee, etc., as appropriate) for himself/ herself, his/er heirs, personal representatives, successors in interest , and assigns, as a part of the consideration hereof, does hereby covenant and agree ( in the case of deeds and leases add, "as a covenant running with the land") that ( 1) no person on the ground of race, color, or national origin, will be excluded from participation in, denied the benefits of, or be otherwise subjected to discrimination in the use of said facilities, (2) that in the construction of any improvements on, over, or under such land, and the furnishings of services thereon, no person on the ground of race, color, or national origin, will be excluded from participation in, denied the benefits or, or otherwise be subjected to discrimination, 3) that the (grantee, licensee, lessee, permittee, etc.) will use the premises in compliance with all other requirements imposed by or pursuant to the Acts and Regulations, as amended, set forth in this Assurance.
B. With respect to ( licenses, leases, permits, etc.) in the event of breach of any of the above of the above Non- discrimination covenants, the California Department of Transportation will have the right to terminate the ( license, permits, etc., as appropriate) and to enter or re- enter and repossess said land and the facilities thereon, and hold the same as if said ( license, permit, etc., as appropriate) had never been made or issued.*
C. With respect to deeds, in the event of breach of any of the above Nondiscrimination covenants, the California Department of Transportation will there upon revert to and vest in and become the absolute property of the California Department of Transportation and its assigns.
Reverter clause and related language to be used only when it is determined that such a clause is necessary to make clear the purpose of Title VI.)
Title VI Implementation Plan
City of Lathrop
20 APPENDIX E
During the performance of this contract, the contractor, for itself, its assignees, and successors in interest hereinafter referred to as the " contractor") agrees to comply with the following non- discrimination statutes and authorities, including, but not limited to: Pertinent Non -Discrimination Authorities:
Title VI of the Civil Rights Act of 1964 ( 42 U. S. C. § 2000d et seq., 78 stat. 252), prohibits discrimination on the basis of race, color, national origin); and 49 CFR Part 21.
The Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, (42 U. S. C. 4601), (prohibits unfair treatment of persons displaced or whose property has been acquired because of Federal or Federal -aid programs and projects); Federal -Aid Highway Act of 1973, (23 U. S. C. § 324 et seq.), prohibits discrimination on the basis of sex;
Section 504 of the Rehabilitation Act of 1973, (29 U. S. C. § 794 et seq.), as amended, ( prohibits discrimination on the basis of disability); and 49 CR Part 27; The Age Discrimination Act of 1975, as amended, ( 42 U. S. C. § 6101 et seq.), prohibits discrimination on the basis of age);
Airport and Airway Improvement Act of 1982, (49 U. S. C. § 471, Section 47123), as amended, prohibits discrimination based on race, creed, color, national origin, or sex); The Civil Rights Restoration Act of 1987, ( PL 100- 209), (Broadened the scope, coverage and applicability of Title VI of the Civil Rights Act of 1964, The Age Discrimination Act of 1975 and Section 504 of the Rehabilitation Act of 1973, by expanding the definition of the terms " programs or activities" to include all of the programs or activities of the Federal - aid recipients, sub -recipients and contractors, whether such programs or activities are Federally funded or not); Titles II and III of the Americans with Disabilities Act, which prohibit discrimination of the basis of disability in the operation of public entities, public and private transportation systems, places of public accommodation, and certain testing entities ( 42 U. S. C. §§ 12131 — 12189) as implemented by Department of Transportation regulations 49 C. F. R. parts 37 and 38; The Federal Aviation Administration' sNon- discrimination statute ( 49 U. S. C. § 47123) ( prohibits discrimination on the basis of race, color, national origin, and sex); Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low -Income Populations, which ensures discrimination against minority populations by discouraging programs, policies, and activities with disproportionately high and adverse human health or environmental effects on minority and low- income populations; Executive Order 13166, Improving Access to Services for Persons with Limited English Proficiency, and resulting agency guidance, national origin discrimination includes discrimination because of limited English proficiency ( LEP). To ensure compliance with Title VI, you must take reasonable steps to ensure that LEP persons have meaningful access to your programs ( 70 Fed. Reg. at 74087 to 74100);
Title IX of the Education Amendments of 1972, as amended, which prohibits you from discriminating because of sex in education programs or activities ( 20 U. S. C. 1681 et seq).
Title VI Implementation Plan
City of Lathrop
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