ITEM 4. 7
CITY MANAGER' SREPORT
MARCH 9, 2026 CITY COUNCIL REGULAR MEETING
ITEM: APPROVE TITLE VI PROGRAM FOR LATHROP
TRANSIT
RECOMMENDATION: Resolution to Authorize the City Manager or Designee to Submit a Title VI Program for Lathrop
Transit to the Federal Transit Administration
SUMMARY:
The City of Lathrop' stransit system, Lathrop Transit, was launched in Quarter 2 of 2025 to improve mobility, accessibility, and transportation equity for residents throughout the City. One of the requirements of being a transit system that receives funds as a Federal Transit Administration ( FTA) direct recipient is the submission of a Title VI Program.
BACKGROUND:
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs and activities receiving federal funds. Every three years, the Federal Transit Administration ( FTA) requires an update of the Title VI Program. With the City of Lathrop starting public transit on April 1, 2025, this will be the first Title VI Program for Lathrop Transit to be submitted to the FTA.
The City, as an FTA recipient is required to adopt a Title VI Program to comply with 49 CFR Section 21. 7(a). The purpose of Title VI is to prohibit discrimination on the basis of race, color, or national origin in programs and activities receiving federal funds. FTA Circular 4702. 1B provide project evaluation guidance for transit agencies when they are considering changes in services and building new infrastructure.
As a result, the FTA requires all of its recipients to include in their Title VI Program:
Title VI Notice to Public, Complaint Procedure, and Complaint Form Limited English Proficiency ( LEP) Plan and a Public Involvement Program A list of investigations, lawsuits, and complaints
Information regarding the location of fixed route facilities Table depicting racial composition of membership of non -elected bodies; and Adoption of service standards and policies.
After the City Council adopts the Title VI Program, all transit and contracted staff will be trained on the topic and the operations contractors will be informed of the Title VI Program. The Title VI Program will also be available to the public to review at Lathrop City HaII and online at www. lathroptransit. com. The policy outlining the procedures for filing a Title VI complaint will be posted in Lathrop Transit vehicles and included in printed materials, as well as made available at the same locations where the public
CITY MANAGER' S REPORT
MARCH 9, 2026 CITY COUNCIL REGULAR MEETING
LATHROP TRANSIT TITLE VI PROGRAM
PAGE 2
may review the complete Title VI Program. The resolution approval reflects the City' s commitment to compliance with Title VI.
REASON FOR RECOMMENDATION:
The City, as an FTA recipient is required to adopt a Title VI Program to comply with 49 CFR Section 21. 7(a). The purpose of Title VI Program is to prohibit discrimination on the basis of race, color, or national origin in programs and activities receiving federal funds. FTA Circular 4702. 1B provide project evaluation guidance for transit agencies when they are considering changes in services and building new infrastructure. The proposed Title VI Program will demonstrate compliance to the FTA.
FISCAL IMPACT:
This item has no direct fiscal impact. Any costs associated with this action are limited to existing staff time and are absorbed within the Council adopted transit budget.
ATTACHMENTS:
A. Resolution to Authorize the City Manager or Designee to Submit a Title VI Program for Lathrop Transit to the Federal Transit Administration B. Lathrop Transit Title VI Program
CITY MANAGER' SREPORT
MARCH 9, 2026 CITY COUNCIL REGULAR MEETING
LATHROP TRANSIT TITLE VI PROGRAM
APPROVALS:
y / z / zoT (v
PAGE 3
Thomas Hedegard Date
Deputy City Manager
3-. 102- 6
Salvador Navarrete Date
City Attorney
4 • Zto
Steen J. Salvatore Date
City Manager
RESOLUTION NO. 26-
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LATHROP TO
AUTHORIZE THE CITY MANAGER OR DESIGNEE TO SUBMIT A TITLE VI
PROGRAM FOR LATHROP TRANSIT TO THE FEDERAL TRANSIT
ADMINISTRATION
WHEREAS, the City of Lathrop' stransit system, Lathrop Transit, was launched in Quarter 2 of 2025 to improve mobility, accessibility, and transportation equity for residents throughout the City. Lathrop Transit is funded through One of the requirements of being a transit system that receives funds as a Federal Transit Administration ( FTA) direct recipient is the submission of a Title VI Program; and WHEREAS, the City of Lathrop is a recipient of Federal Transit Administration FTA) revenues and is required to meet federal regulatory requirements for the Title VI, established by 49 C. F. R. part 21. 7; and
WHEREAS, the FTA requires that the City of Lathrop provide a Title VI Program and Limited English Proficiency Plan that ensures that no person or group of persons on the basis of race, color, or national origin is subjected to discrimination in the level and quality of transportation services and benefits and that steps are taken to ensure that persons with limited English proficiency are provided these rights; and WHEREAS, the City developed a Title VI Program and accompanying Limited English Proficiency Plan based on best practices that meet FTA guidelines.
NOW, THEREFORE, BE IT RESOLVED, that the City Council of the City of Lathrop authorizes the City Manager or Designee to Submit a Title VI Program for Lathrop Transit to the Federal Transit Administration.
The foregoing resolution was passed and adopted this 9th day of March 2026, by the following vote of the City Council, to wit:
AYES:
NOES:
ABSTAIN:
ABSENT:
Paul Akinjo, Mayor
ATTEST: APPROVED AS TO FORM:
Teresa Vargas, City Clerk Salvador Navarrete, City Attorney ATTACHMENT " ''
11111111
i
LATHROP TRANSIT -
Community Driven"
Title VI Program
October 1, 2025 to September 3, 2028
L- th- rOctober 2025
RECIPIENT INFORMATION
RECIPIENT:
SUBMITTAL DATE:
PROGRAM UPDATE:
EXPIRATION YEAR:
CONTACT INFORMATION:
City of Lathrop on behalf of Lathrop Transit ( Lathrop Transit) March 10, 2026
October 1, 2025, for the incorporation of Federal Transit Administration policy and Governing Board adoption on a minimum three- year period.
2028
John C. Andoh III, Transit Planning & Management Consultant 390 Towne Center Drive, Lathrop, CA 95330
Phone: 209. 321. 1334
transit@ci. lathrop. ca. us
ii
PROVISION OF TITLE VI ASSURANCES
The City of Lathrop on behalf of Lathrop Transit ( Lathrop Transit) hereby certifies that, in accordance with 49 CFR Section 21. 7(a), it will ensure that:
1. Lathrop Transit shall submit, on an annual basis, its Title VI Assurances, as part of its annual Certification and Assurances submission to the FTA
2. No person, on the basis of race, color, or national origin, will be subjected to discrimination in the level and quality of transportation services and transit - related benefits
3. Lathrop Transit will compile, maintain, and submit in a timely manner, Title VI information required by FTA Circular 4702. 1 B
4. Lathrop Transit will make it known to the public that persons alleging discrimination on the basis of race, color, or national origin as it relates to the provision of transportation services and transit - related benefits may file a complaint with the FTA and/ orthe U. S. Department of Transportation ( USDOT).
I. TITLE VI COMPLIANCE HISTORY
1. There are no outstanding lawsuits or complaints naming Lathrop Transit which allege discrimination on the basis of race, color or national origin with respect to service or other transit benefits.
2. During the course of the last three ( 3) years, there have not been any civil rights compliance review activities conducted with respect to Lathrop Transit and, to the best of our knowledge, there are not presently any ongoing civil rights compliance review activities being conducted with respect to Lathrop Transit.
3. There are currently no pending construction projects which would negatively impact minority communities being performed by Lathrop Transit.
II. INCORPORATION OF THE PROGRAM
The City of Lathrop on behalf of Lathrop Transit (hereinafter referred to as " Lathrop Transit" or "Recipient") hereby agrees that, as a condition to receiving any Federal financial assistance from the Department of Transportation, it will comply with Title VI of the Civil Rights Act of 1964, 78 Stat. 252, 42 U. S. C. 2000d42 U. S. C. 2000d- 4 (hereinafter referred to as the " Act"), and all requirements imposed by or pursuant to Title 49, Code of Federal Regulations, Department of Transportation, Subtitle A, Office of the Secretary, Part 21, Nondiscrimination in Federally Assisted Programs of the Department of Transportation - Effectuation of Title VI of the Civil Rights Act of 1964 ( hereinafter referred to as the " Regulations"), and other pertinent directives. 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 otherwise subjected to discrimination under any program or activity for which Lathrop Transit receives Federal financial assistance from the Department of Transportation, including the Federal Transit Administration ( FTA), and HEREBY GIVES ASSURANCE THAT it will promptly take any measures necessary to effectuate this agreement. This assurance is required by subsection 21. 7(a) of the Regulations.
More specifically, and without limiting the above general assurance, Lathrop Transit hereby gives the following specific assurances with respect to its FTA program:
1. That Lathrop Transit agrees that each " program" and each " facility", as defined in subsections
21. 23( e) and 21. 23( b) of the Regulations will be ( with regard to a " program") conducted or will be ( with regard to a " facility") operated, in compliance with all requirements imposed by, or pursuant to, the Regulations.
3 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028
2. That Lathrop Transit shall insert the following notification in solicitations for sealed bids and request for proposals for large procurements related to work or material subject to the Regulations and made in connection with all FTA programs and, in adapted form in all proposals or negotiated agreements:
The City of Lathrop on behalf of Lathrop Transit, in accordance with Title VI of the Civil Rights Act of 1964, 78 Stat. 252, 42 U. S. C. 2000d to 2000d- 4and Title 49, Code of Federal Regulations, Department of Transportation, Subtitle A, Office of the Secretary, Part 21, Nondiscrimination in Federally -Assisted Programs of the Department of Transportation issued pursuant to such Act, hereby notifies all bidders/ proposers that it will affirmatively insure that in any contract entered into pursuant to this advertisement, minority business enterprises will be afforded full opportunity to submit bids in response to the invitation and will not be discriminated against on the grounds of race, color, or national origin in consideration for an award.
3. That Lathrop Transit shall insert the applicable clauses as per the most recent version of the FTA' s Best Practices Procurement Manual in every contract subject to this Act and the Regulations.
4. That Lathrop Transit shall include the appropriate clauses as per the most recent version of the FTA' s Best Practices Procurement Manual as a covenant running with the land, in any deed from the United States affecting a transfer of real property, structures, or improvements thereon, or interest herein.
5. That where Lathrop Transit receives Federal financial assistance to construct a facility, or part of a
facility, the assurance shall extend to the entire facility and facilities operated in connection therewith.
6. That where Lathrop Transit receives Federal financial assistance in the form, or for the acquisition of real property or an interest in real property, the assurance shall extend to rights to space on, over or under such property.
7. That Lathrop Transit shall include the appropriate clauses as per the most recent version of the FTA' s Best Practices Procurement Manual as a covenant running with the land, in any future deeds, leases, permits, licenses, and similar agreements entered into by Lathrop Transit with other parties: (a) for the subsequent transfer of real property acquired or improved under FTA programs; and ( b) for the construction or use of, or access to, space on, over, or under real property acquired, or improved under FTA programs.
8. That this assurance obligates Lathrop Transit for the period during which Federal financial assistance is extended to the program, except where the Federal financial assistance is to provide, or is in the form of personal property or real property or interest therein or structures or improvements thereon, in which case the assurance obligates Lathrop Transit or any transferee for the longer of the following periods: (a) the period during which the property is used for a purpose for which the Federal financial assistance is extended, or for another purpose involving the provision of similar services or benefits; or ( b) the period during which Lathrop Transit retains ownership or possession of the property.
9. Lathrop Transit shall provide for such methods of administration for the programs as are found by the Secretary of Transportation or the official to whom he/ she delegates specific authority to give reasonable guarantee that it, other interest, and other participants of Federal financial assistance under such program will comply with all requirements imposed or pursuant to the Act, the Regulations and this assurance.
4 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028
10. Lathrop Transit agrees that the United States has a right to seek judicial enforcement with regard to any matter arising under the Act, the Regulations, and this assurance.
11. Lathrop Transit assures that the level and quality of transit service and related benefits are provided in a manner consistent with the Title VI of the Civil Rights Act of 1964.
12. Lathrop Transit assures that the public will be given notice and engaged in a public hearing for service and fare adjustments in accordance with the adopted Lathrop Transit policy.
THESE ASSURANCES are given in consideration of, and for the purpose of, obtaining any and all Federal grants, loans, contracts, property, discounts or other Federal financial assistance extended after the date hereof to the City of Lathrop on behalf of Lathrop Transit by the United States Department of Transportation under the Federal Administration and is binding on it, other recipients, subgrantees, contractors, transferees, successors in interest and other participants in the FTA programs.
The person whose signature appears below is authorized to sign these assurances on behalf of Lathrop Transit.
Thomas Hedegard
Deputy City Manager
October 1, 2025
Date
Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 5 GENERAL GUIDELINES/ REQUIREMENTS
I. Annual Certification and Assurance
As stated in Section I, Lathrop Transit shall submit annually, its Title VI assurance, as part of its annual Certification and Assurance submission to the FTA. The most recent submission for Lathrop Transit was executed and submitted to the FTA on August 11, 2025.
II. Complaint Procedures
In compliance with 49 CFR Section 21. 9(b), Lathrop Transit has developed procedures for investigating and tracking Title VI complaints filed against them. Such procedures shall be made available to the public upon request. Lathrop Transit' scomplaint procedures and complaint form are contained herein as APPENDIX A.
III. Record Title VI Activities
In compliance with 49 CFR Section 21. 9(b), Lathrop Transit shall prepare and maintain a list of any active investigations conducted by entities other than the FTA, lawsuits, or complaints naming Lathrop Transit that allege discrimination on the basis of race, color, or nation origin. contained herein as APPENDIX B.
Such list shall include:
1. Date the investigation, lawsuit, or complaint was filed
2. Summary of the allegation( s)
3. The status of the investigation, lawsuit, or complaint
4. Actions taken by Lathrop Transit in response to the investigation, lawsuit or complaint IV. Access for LEP Persons
Lathrop Transit shall take steps to ensure meaningful access to the benefits, services, information, and other important portions of their programs and activities for individuals who are Limited English Proficient LEP). Lathrop Transit will assist persons with limited English proficiency to participate in the transportation planning process. Lathrop Transit Staff will make every effort to provide translators and document translation, where feasible, upon request. Lathrop Transit' s LEP Plan is contained herein as APPENDIX D.
V. Public Notification
In compliance with 49 CFR Section 21. 9(d), Lathrop Transit shall provide information to the public regarding its Title VI obligations and apprise members of the public of the protections against discrimination afforded to them by Title VI by the following notice:
NOTICE of RIGHTS UNDER TITLE VI
The City of Lathrop on behalf of Lathrop Transit ( Lathrop Transit) operates its programs and services without regard to race, color, and national origin in accordance with Title VI of the Civil Rights Act. Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with Lathrop Transit. It is Lathrop Transit' sobjective to:
Ensure that the level and quality of transportation service is provided without regard to race, color, or national origin
6 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Promote the full and fair participation of all affected populations in transportation decision -making
Prevent the denial, reduction, or delay in benefits related to programs and activities that benefit minority populations or low- income populations Ensure meaningful access to programs and activities by persons with limited English proficiency
For more information Lathrop Transit' scivil rights program and the procedures to file a complaint, call 209. 941. 7220; email: transit@ci. lathrop. ca. us; visit our website, www. lathroptransit. com; or visit our administrative office at 390 Towne Center Drive, Lathrop CA 95330. Any complaint must be in writing and submitted to the Lathrop Transit Manager ( as the Title VI Coordinator) within one hundred eighty ( 180) days following the date of the alleged unlawful discriminatory practice.
A complainant may file a complaint directly with the Federal Transit Administration, Office of Civil Rights, Attention: Title VI Program Coordinator, East Building, 5th Floor- TCR, 1200 New Jersey Ave., SE, Washington, DC 20590.
If information is needed in another language, contact 209. 941. 7220. Si necesita informacion en otro idioma, contacto 209. 941. 7220.
The Lathrop Transit Notice of Rights under Title VI to the public, shown above, is posted in the Lathrop Transit Administrative Offices and on buses, shown online at www. lathroptransit. com, and within the Lathrop Transit Rider' s Guide.
VI. Additional Information
Lathrop Transit acknowledges that, at the discretion of the FTA, information other than that which is required by FTA C 4702. 1B, may be requested in writing of Lathrop Transit, to investigate complaints of discrimination or to resolve concerns about possible noncompliance with Title VI.
VII. Timely Submission
Lathrop Transit acknowledges that its Title VI submissions and/ or updates thereto, shall be supplied to its FTA Office of Civil Rights once every three ( 3) years. The submission shall include but is not limited to:
1. A summary of public outreach and involvement activities undertaken since the last submission and a description of any steps taken to ensure that minority and low- income people had meaningful access to these activities APPENDIX C
2. Lathrop Transit' sprocess for persons with Limited English Proficiency ( LEP)
3. Title VI complaint and Tracking procedures
4. A list of any Title VI investigations, complaints or lawsuits filed since the latest submission.
5. A copy of Lathrop Transit' spublic notice regarding Title VI compliance and public access and instructions to Lathrop Transit Title VI complaint procedures.
VIII. Environmental Analysis of Construction Projects
Lathrop Transit shall integrate an environmental justice analysis into its National Environmental Policy Act ( NEPA) documentation of construction projects of which require NEPA. If a Categorical Exclusion CE) is performed, Lathrop Transit shall complete the FTA' sstandard CE checklist which includes a section on community disruption and environmental justice. While preparing an Environmental Assessment ( EA) or Environmental Impact Statement ( EIS), Lathrop Transit shall integrate into its documents, the following:
7 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028
1. A description of the low- income and minority population within the study area affected by the project, and a discussion of the method used to identify this population
2. A discussion of all adverse effects that would affect the identified minority and lowincome population
3. A discussion of all positive effects that would affect the identified minority and lowincome population
4. A description of all mitigation and environmental enhancement actions incorporated into the project to address the adverse effects, including, but not limited to, any special features of the relocation program that go beyond the requirements of the Uniform Relocation Act and address adverse community effects such as separation or cohesion issues, and the replacement of the community resources destroyed by the project.
And if applicable:
5. A discussion of the remaining effects, if any, and why further mitigation is not proposed
6. For projects that traverse predominantly minority and low- income and predominantly non - minority and non - low- income areas, a comparison will be completed of mitigation and environmental enhancement actions between the two stated areas. If there is no basis for such a comparison, Lathrop Transit shall describe why this is the case.
IX. Public Participation
Lathrop Transit shall seek out and consider viewpoints of minority, low- income and LEP populations in the course of conducting public outreach and involvement activities in regard to proposed transportation decisions. Lathrop Transit shall make every effort to include the following practices, consistent with the San Joaquin Council of Governments adopted Public Involvement Plan ( available https:// www. sicoq. or/ 127/ Public- Participation- Plan); as well as the public participation plan adopted by the Lathrop City Council as part of this program:
1. Coordination with individuals, institutions, or organizations and implementing community - based public involvement strategies to reach out to members in the affected minority and/ or low- income communities
2. Provision of opportunities for public participation through means other than written communication, such as personal interviews or use of audio or video recording devices to capture oral comments
3. Utilization of locations, facilities and meeting times that are convenient and accessible to low- income and minority communities
4. Utilization of different meeting sizes or formats, or varying the type and number of news media used to announce public participation opportunities
5. Implementation of USDOT' spolicy guidance regarding Lathrop Transit' sresponsibilities to LEP persons.
Since April 1, 2025 the public outreach activities occurred related to informing the community and other stakeholders about Lathrop Transit in an effort to build awareness and ridership. The City did have two workshops, one in -person and one online to -gather feedback on the development of a transit system in 2024, in conjunction with San Joaquin Regional Transit District. Lathrop Transit is the City' sfirst transit system created since its incorporation in 1989.
When Lathrop Transit implements changes to its operations, public outreach activities will be designed and accomplished to ensure the public was aware of such changes. For service, fare and route adjustments, changes to service announcements were made 30 days prior to the adjustment to encourage feedback from passengers and a draft of the route schedule was posted to the website. A survey or communication channel was established for passengers to provide their feedback and then 8 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 those comments were analyzed and taken into consideration. The public was made aware of changes through various channels including public notice on website, notice in newspaper ( as necessary), social media announcements, email announcements, text messages, signage at bus stops, and flyers on buses. Final adjustments were then prepared and, if necessary and required, presented to the Lathrop City Council to have a vote and establish the date the adjustments to become effective.
The City will encourage the public to attend any Lathrop City Council meeting. A two ( 2) to three ( 3) week period of time will be provided for passengers to see the final adjustments, ask questions, and understand the adjustments prior to it becoming effective. Announcements of final adjustments will be made through similar channels as the initial announcement to encourage passengers to review the adjustments.
See APPENDIX C for a
summary list of dates over the past three ( 3) years that Lathrop Transit has adjusted routes or fares.
Public Participation Plan
Strategies and Desired Outcomes
To promote inclusive public participation, the Lathrop Transit will employ the following strategies, as appropriate:
Provide for frequent and continuous engagement by the public Select varied meeting locations and times that are convenient and accessible for minority and Limited English Proficient ( LEP) communities
Coordinate with community organizations, educational institutions, and other organizations to implement public engagement strategies that reach out specifically to members of affected minority and/ or LEP populations
Use media in addition to other resources as a way to gain public involvement to include publications, notifications, and invitations that serve LEP populations Lathrop Transit is committed to informing and involving the public in the planning and delivery of public transportation services in its service area and will comply with state and federal laws and regulations including Title VI of the Civil Rights Act of 1964 which states that " no person in the United States shall, on the ground of race, color, or national origin be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance." Pursuant to the Federal Transportation Administration Title VI Circular FTA C 4702. 1B, "Every Title VI program shall include an outreach plan to engage minority and limited English proficient populations, as well as a
summary of outreach efforts made since the last Title VI submission." The City Council allows for public participation for all transit items that require the City Council approval which include: funding agreements, procurement of subcontractors, and purchase of service agreements. The City Council also allows public comment on all agenda items it considers. In addition, any member of the public may address the City Council on any non -agenda item, including transit, at any of its regular meetings. Meeting agendas are posted at least 72 hrs. in advance of the meeting and are available at www. ci. lathrop. ca. us.
The City actively participates in the committees and councils through the San Joaquin Council of Governments, which includes the Interagency Transit Committee, Technical Advisory Committee and the Social Services Transportation Advisory Council well as Access San Joaquin, the Consolidated Transportation Service Agency for San Joaquin County.
The City actively participates in the development of the Transportation Improvement Program ( TIPs) administered by San Joaquin Council of Governments. TIP must include all major capital projects in order to receive federal funding. TIP meetings are open to the public with agendas posted 72 hours in advance and available on the SJCOG website at http:// www. sjcog. or. 9 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 The City conducts regular surveys of its ridership and maintains a record of all complaints. This information is reviewed and considered when relevant projects, service changes, or other operational issues are being planned or considered. The City has conducted transportation studies for transit service needs. All studies and any possible proposed service changes were discussed/ presented in several stakeholder and public meetings to adequately obtain the public' sinput. Other methods of public outreach were done by press release and the use of social media outlets.
The City may also conduct public informational meetings to obtain public comment when it is considering fare changes, significant route alterations, major capital improvements, or other service or system changes for which the County believes public input is warranted. The City may also proactively schedule presentations before faith -based organizations, community organizations or at community gatherings where members of the public are likely to be in attendance and use Lathrop Transit services that may be affected by proposed changes.
In such cases, the following process will be utilized:
City of Lathrop Public Participation Process
Outline project for which public participation process is sought Prepare/ update mailing and email lists of key stakeholders and community interests Prepare/ post/ublish, as appropriate, notice of public participation opportunity which may take the form of surveys, public meetings, invitation for comment or other in -put mechanisms
Develop and make available project outline and information materials along with relevant City standards/ policies, project goals and objectives and how to provide input.
Maintain a record of public input process, activities and input received.
Since the start of Lathrop Transit, the City has conducted regular community engagement and outreach via traditional media, social media, and through on - board customer service.
X. Public Hearing Process for Service and Fare Changes
The City will advertise in accordance with this policy regarding public participation to conduct any public hearing when considering proposed fare and major service changes. Public hearings are a key element of the decision - making process used by the Lathrop City Council to assess the potential impact proposals that may have on Lathrop Transit riders and residents.
Policy
Public hearings will be scheduled by the Lathrop City Council for fare and major service change proposals except as otherwise provided below.
Definitions
A major service or fare change is any change or series of changes that directly affect:
1. 25 percent or more reduction of transit route revenue hours of Lathrop Transit system -wide service.
2. 50 percent or more reduction of transit route revenue hours of a single Lathrop Transit route computed on an annual basis.
3. The implementation of a new transit route.
4. 25 percent or more on the implementation of a passenger fare adjustment on an annual basis.
10 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Procedure
Proposed major service changes and fare and fare media pricing shall be evaluated for compliance with the FTA Office of Civil Rights guidance regarding potential discriminatory impacts on minority and lowincome populations. The evaluation will include proposed actions the Lathrop Transit may apply to minimize, mitigate, or offset the adverse effects the changes could have on these populations, as described in FTA Circular 4702. 1B, "Title VI and Title VI -Dependent Guidelines." Prior to the institution of a fare change or major service change, a notice of intent to hold a public hearing will be published following the Lathrop City Council adopted public participation plan. The notice will also be published in newspapers oriented to specific groups or neighborhoods that may be affected.
The notice will be published at least 30 days prior to the hearing.
The notice will contain descriptions of the changes and the time and place of the hearing.
Lathrop Transit shall ensure that all programs, services, activities, and benefits are implemented without discrimination. Any person who believes that he or she, individually, or as a member of any specific class or persons, has been subjected to discrimination on the basis of race, color, national origin, or other protected class interests, may file a signed written complaint with Lathrop Transit or FTA at the addresses listed below:
City of Lathrop on behalf of Lathrop Transit
390 Towne Center Drive
Lathrop, CA 95330
Email: transit@ci. lathrop. ca. us
Federal Transit Administration Office of Civil Rights
Title VI Program Coordinator
East Building, 5th Floor — TCR
1200 New Jersey Avenue, SE
Washington, DC 20590
If you are unable or incapable of providing a written statement and desire Lathrop Transit or the FTA to investigate alleged discrimination, a verbal complaint of discrimination may be made. You may call Lathrop Transit at 209. 941. 7220. The complainant will be interviewed by City staff to receive complaints.
If necessary, the official will assist the complainant in converting verbal complaints in writing. All Complaints must be signed by the complainant or his/er representative.
Exceptions
1. Changes in fares and fare media pricing are subject to public hearing requirements with the exception of the following:
Reduced fare for less than 180 days
Free -fare promotions.
2. Service changes are subject to public hearing requirements with the exception of the following:
Standard seasonal variations.
Changes instituted in response to an emergency situation in effect for 90 days or less.
11 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Experimental service changes are instituted for 180 days or less.
Nothing in this section precludes the Lathrop City Council from setting a public hearing on any matter associated with fares and service that it chooses.
Furthermore, all changes contemplated by Lathrop Transit will be reviewed by the Lathrop City Council.
XI. Plan Monitoring and Evaluation
Evaluation of the success of any involvement efforts must be result -oriented. It is never safe to assume that just because people don' t come to an event that they are uninterested in the project. The goal is to educate and include the public at all levels of planning, not just to invite them. Evaluation, then, must be two -fold. The first part is to track what efforts are being made, and the results of those efforts, and the second part is to make regular assessments of the success of a technique within a given program, and
to strategize for future successes.
Tracking Efforts and Success
In order to track our public participation efforts, it is necessary that the individuals involved record their efforts.
1. Lathrop Transit will keep records of outreach activities. See a summary in APPENDIX C.
2. Copies should be kept of any print ads, and transcripts of any public service announcements.
3. Notes should be made after meetings regarding the overall tone of the meetings and any ideas or observations made regarding the process.
Efforts of Monitoring and Evaluation of the LEP Plan
1. Provide day- to- day administration of Lathrop Transit' sLEP Plan, ensuring compliance and correct implementation.
2. Seek feedback from LEP communities, including customers and community -based organizations, about the effectiveness of Lathrop Transit' sLEP Plan.
3. Translate Lathrop Transit' sTitle VI complaint procedure and form in multiple languages.
4. Establish a Lathrop Transit procedure that requires all written translation requests be routed through and managed by the Title VI coordinator to ensure consistency.
5. Create one -stop LEP information center for Lathrop Transit riders.
6. Conduct an evaluation every three ( 3) years of Lathrop Transit' s LEP Plan to gauge its effectiveness and determine if updates are needed. Lathrop Transit staff will lead the evaluation with the help of staff familiar with Title VI language access requirements and the LEP Plan. The evaluation may include the following:
Determine the number of LEP individuals in Lathrop Transit' sservice area.
Assess whether existing language assistance services are meeting the needs of LEP persons.
Assess whether staff members understand Lathrop Transit' sLEP Plan, how to carry them out, and whether language assistance resources and arrangements for those resources are still current and accessible.
XI. Monitoring Subrecipients
Lathrop Transit does not have any sub -recipients. So, no oversight is needed in this area. 12 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 XII. Minority Representation on Planning and Advisory Bodies Lathrop Transit does not have any planning and advisory bodies. So, no oversight is needed in this area.
XIII. Title VI Equity Analysis
Lathrop Transit has not constructed afacility such as a vehicle storage facility, maintenance facility, or operations center. Should this be constructed, an equity analysis will be prepared.
XIV. Service Standards
Vehicle Load Standard
Lathrop Transit operates local bus transportation services throughout the city limits of Lathrop. The average of all loads during the peak and off- peak operating periods should not exceed a load factor of
1. 4. Refer to chart below for current standards:
Vehicle Type Average Passenger Capacities
Seated Standing Total Load Factor
Van 9 0 9 1. 4
Cutaway 16 5 21 1. 4
Vehicle Headways
Service AM Peak Midday PM Peak Evening
School Tripper 60 min 60 min
Peak 6 am — 9 am, 3 pm — 6 pm, Off -Peak 9 am — 3 pm, Evening 6 pm — 9: 15 pm; "— no service.
On -Time Performance Standard
Lathrop Transit routes are to be considered on time if they are no more than " 0" minute early and no more than " 5." minutes late leaving a time -point on a scheduled trip. The on -time performance goal is set at 90% or greater. Lathrop Transit will continuously monitor the various routes throughout the system to maintain this standard.
Service Availability Standard
Lathrop Transit routes are designed to serve the city limits of Lathrop. Lathrop Transit provides access to major employment centers, central business districts, schools and hospitals. Connectivity is available to Altamont Corridor Express ( ACE), San Joaquin Regional Transit District ( RTD), Manteca Transit and Ride the S ( Stanislaus County). Stops are generally spaced every 1/ 2 mile along the routes.
XV. Service Policies
Lathrop Transit Amenities Policy
Policy: In accordance with Title VI of the Civil Rights Act, as amended it shall be the policy of the City of Lathrop on behalf of Lathrop Transit to assign amenities without regard to race, color, ethnicity and national origin. Amenity assignment refers to the process of placing amenities along various routes within the Lathrop Transit system.
13 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Procedures: The installation of transit amenities shall be primarily based on the number of passenger boarding' sat bus stops and park & ride lots along the route. These amenities include but are not limited to the following: seating, benches, shelters, informational signs, maps and schedules, digital and electronic signs, solar lighting and waste receptacles. Additional requirements for placement include safety, proper zoning approval if necessary and meeting all applicable building and construction laws.
Request for transit amenities can be submitted through the Lathrop Transit Call Center or at transit( aci. lathrop. ca. us. Each request will be reviewed in a timely manner.
Lathrop Transit Vehicle Assignment Policy
Policy: In accordance with Title VI of the Civil Rights Act, as amended it shall be the policy of the City of Lathrop on behalf of Lathrop Transit to assign vehicles without regard to race, color, ethnicity and national origin.
Procedures: All bus routes are ADA accessible and are equipped with a voice annunciation stop announcement system, wheelchair ramps, bus kneeling feature, bicycle racks, air conditioning, heating and destination signage.
Bus assignments consider the operating characteristics such as length, width, height and the turning radius of the bus. The physical route requirements are taken into consideration when assigning buses.
Related Documents:
FTA Circular 4702. 1B, Title VI Requirements and Guidelines for FTA Recipients.
The person whose signature appears below is authorized to sign on behalf of Lathrop Transit.
Thomas Hedegard
Deputy City Manager
October 1, 2025
Date
Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 14 APPENDIX A : TITLE VI COMPLAINT PROCEDURES
Title VI Information, Limited English Proficient (LEP) information and Complaint Process Printed materials, website, and other mediums upon request) The City of Lathrop on behalf of Lathrop Transit grants all citizens equal access to all its transportation services. It is further the intent of Lathrop Transit that all citizens are aware of their rights to such access.
This is designed to serve as an educational tool for citizens so that they may understand one of the civil rights laws that protect their benefits of Lathrop Transit' s programs and services, specifically, as it relates
to Title VI of the Civil Rights Act of 1964.
What is Title VI? Title VI is a section of the Civil Rights Act of 1964 requiring 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." Note that Title VI does not address gender discrimination. It only covers race, color and national origin. Other Civil Rights laws prohibit gender discrimination.
What is LEP? As part of Title VI requirements, Lathrop Transit has developed a Limited English Proficiency ( LEP) Plan to help identify reasonable steps to provide language assistance for LEP persons seeking meaningful access to Lathrop Transit services as required by the FTA " Improving Access to Services for Persons with Limited English Proficiency." A Limited English Proficiency person is one who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English.
Lathrop Transit' s Complaint and Investigation Procedures These procedures cover all complaints filed under Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act of 1990, for alleged discrimination in any program or activity administered by Lathrop Transit. These procedures do not deny the right of the complainant to file formal complaints with other State or Federal agencies or to seek private counsel for complaints alleging discrimination.
Every effort will be made to obtain early resolution of complaints at the lowest level possible. The option of informal mediation meeting( s) between the affected parties and Lathrop Transit may be utilized for resolution. Any individual, group of individuals or entity that believes they have been subjected to discrimination prohibited under Title VI and related statutes may file a complaint.
The following measures will be taken to resolve Title VI complaints:
Title VI Complaint Procedure
Title VI complaint forms may download from www. lathroptransit. com or requested from ( Lathrop Transit).
The complainant may also submit a written statement that contains all the following information:
1. Name, address, and telephone number of the complainant.
2. The basis of the complaint ( race, color, national origin).
3. The date or dates on which the alleged discriminatory event or events occurred.
4. The nature of the incident that led the complainant to feel discrimination was a factor. 15 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028
5. Names, addresses and telephone numbers of persons who may have knowledge of the event.
6. Other agencies or courts where complaint may have been filed and a contact name.
7. Complainant' ssignature and date.
If the complainant is unable to write a complaint, Lathrop Transit staff will assist the complainant. If requested by complainant, Lathrop Transit will provide alanguage or sign interpreter.
Complainants have the right to complain directly to the appropriate federal agency. Complaints must be filed within one -hundred eighty ( 180) calendar days of the alleged incident.
Lathrop Transit will begin an investigation within fifteen ( 15) working days of receipt of a complaint.
Lathrop Transit will contact the complainant in writing no later than thirty ( 30) working days after receipt of complaint for additional information, if needed. If the complainant fails to provide the requested information in a timely basis, Lathrop Transit may administratively close the complaint.
Lathrop Transit will complete the investigation within ninety ( 90) days of receipt of the complaint. If additional time is needed for investigation, complainant will be contacted. A written investigation report will be prepared by the investigator. This report shall include a summary description of the incident, findings and recommended corrective action.
A closing letter will be provided to the complainant and the respondent or respondent department.
Parties will have five ( 5) working days from receipt of the closing letter to appeal. If neither party appeals, the complaint will be closed.
If required, the investigation report will be forwarded to the appropriate federal agency.
Federal Transit Administration Office of Civil Rights
Attention: Title VI Program Coordinator
East Building, 5th Floor- TCR
1200 New Jersey Avenue, SE
Washington, DC 20590
FTA complaint procedures can also be found on the FTA web site at: ww. fta. dot. iov. These procedures are also outlined in FTA Circular 4702. 1B, Chapter IX.
A Title VI complaint must be submitted in writing. Lathrop Transit strongly encourages the use of the Lathrop Transit Title VI Complaint Form or sending an email when filing official complaints. Upon completion of a Lathrop Transit Title VI Complaint Form, send it to: email transit( aci. lathrop. ca. us or by mail to: 390 Towne Centre Drive, Lathrop, CA 95330, Attn: Title VI Complaints. 16 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028
TITLE VI COMPLAINT FORM
The City of Lathrop on behalf of Lathrop Transit operates it programs and services without regard to race, color and national origin in accordance with Title VI of the Civil Rights Act of 1964. Any person who believes that she or he has been aggrieved by any unlawful discriminatory practice under Title VI must file a complaint within 180 days of the alleged occurrence to any of the following by mail, in person, fax and/ or email as explained at the end of the form.
a
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Name:
Address:
Telephone ( Home): Telephone ( Work):
Electronic Mail Address:
Accessible Format Requirements?
Large Print Audio Tape
TDD Other
Are you filing this complaint on your own behalf? Yes'` No If you answered " yes" to this question, go to Section III.
If not, please supply the name and relationship of the
person for whom you are complaining.
Please explain why you have filed for a third party:
Please confirm that you have obtained the permission of the aggrieved party if you are filing on behalf of a third party.
Yes No
nw
lli rt ' pT p
Mf
n ii '- ' RM#
x
i@ ti . w a$`:." xaS^ .P9R
I believe the discrimination I experienced was based on ( check all that apply):
Race Color National Origin Disability
Date of Alleged Discrimination ( Month, Day, Year):
Explain as clearly as possible what happened and why you believe you were discriminated against.
Describe all persons who were involved. Include the name and contact information of the person( s) who discriminated against you ( if known) as well as names and contact information of any witnesses. If more space is needed, please use the back of this form.
Have you previously filed a discrimination complaint with this agency? Yes ONo If yes, please provide any reference information regarding your previous complaint. 17 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 4•,• a-:` ,. u_ ..,, i^.2 v3 z; - k`-' t x x .. ¢ z4- s .., W .. . ` Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or State court?
Yes No
If yes, check all that apply:
Federal Agency:
Federal Court: State Agency:
State Court : Local Agency:
Please provide information about a contact person at the agency/ court where the complaint was filed.
Name:
Title:
Agency:
Address:
Telephone:
s x,. 4 f
1'
Tr * ...# z ^
J - « .$.".-' s
5 i„;'*"` . d :
Sai {: 4 :
i 4
Name of agency complaint is against:
Name of person complaint is against:
Title:
Location:
Telephone Number ( if available):
You may attach any written materials or other information that you think is relevant to your complaint. Your signature and date are required below
Signature
Mail, fax, email or deliver completed form to:
City of Lathrop, Attn: Title VI Complaints, 390 Towne Centre Drive, Lathrop, CA 95330, or email to:
transit@ci. lathrop. ca. us.
Federal Transit Administration ( FTA), Office of Civil Rights, Attn: Title VI Program Coordinator, East Building, 5th Floor- TCR, 1200 New Jersey Ave, SE, Washington, DC 20590.
Date
If any transit related information is needed in an alternative language, contact the Lathrop Transit Manager at 390 Towne Centre Drive, Lathrop, CA 95330, call to: 209. 941. 7220 or email to: transit( aci. Iathrop. ca. us. mmINIE 1
a
O1
LATHROP TRANSIT —
Community Driven"
18 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028
CIUDAD DE LATHROP ( LATHROP TRANSIT) TITULO VI FORMULARIO DE QUEJA La Ciudad de Lathrop opera sus programas y
servicios sin distincion de raza, color y origen nacional de acuerdo con el Titulo VI de Ia Ley de Derechos Civiles de 1964. Cualquier persona que crea que ha sido perjudicada por alguna practica discriminatoria ilegal bajo el Titulo VI debe presentar una queja dentro de los 180 dias de la supuesta ocurrencia a cualquiera de los siguientes por correo, en persona, fax y / o correo electronico como se explica al final del formulario.
Nombre:
Telefono ( Casa):
Telephone ( Home): Telefono ( Traba' o):
Direccion de correo electronico:
Requisitos de formato accesible? Impresion grande Cinta de audio TDD Otro
Esta presentando esta queja en su propio nombre? I Si * I No Si respondio " si" a esta pregunta, vaya a la Seccion III.
De Io contrario, proporcione el nombre y
la relacion
de la persona por la que se queja.
Explique por que ha solicitado un tercero:
Confirme que ha obtenido el permiso de la parte perjudicada resentando una demand en nombre de un tercero
si esta
Si
en ( marque todo to que corresponda):
No
a
de la
de los
Creo que la discriminacion que experiments se baso
Raza Color Origen nacional Discapacidad
Fecha de presunta discriminacion ( mes, dia, ano):
Explique con la mayor claridad posible que sucedio y por que cree que fue discriminado. Describe todas las personas que estuvieron involucradas. Incluya el nombre y la informacion de contacto
persona ( s) que to discrimino ( si Io conoce), asi como los nombres y la informacion de contacto
testigos. Si necesita mas espacio, utilice la parte de atras de este formulario. 6 "`.£
L, Ha presentado anteriormente una queja por discriminacion con esta agencia? Si No
En caso afirmativo, proporcione cualquier informacion de referencia con respecto a su queja anterior.
Have you filed this complaint with any other Federal,
court?
Si No
En caso afirmativo, marque todo to que corresponds:
State, or local agency, or with any Federal or State
Tribunal Federal:
Tribunal Federal: Agencia Estatal:
Tribunal estatal: Agencia local:
19 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Proporcione informacion sobre una persona de contacto en la agencia / tribunal donde se presento la c ue' a.
Nombre:
Titulo:
Agencia:
Direccion:
Telefono
7j
El nombre de la cue' ade la agencia este en contra:
La que' adel nombre de la persona es contra:
Titulo:
Ubicacion:
Numero de telefono ( si este disponible):
Puede adjuntar cualquier material escrito u otra informacion que considere relevante para su reclamo. Su firma y fecha son requeridas a continuacion
Firma
Envie por correo, fax, correo electronico o entregue el formulario completo a:
City of Lathrop, Attn: Title VI Complaints, 390 Towne Centre Drive, Lathrop, CA 95330, or email to:
transit@ci. lathrop. ca. us.
Federal Transit Administration ( FTA), Office of Civil Rights, Attn: Title VI Program Coordinator, East Building, 5th Floor- TCR, 1200 New Jersey Ave, SE, Washington, DC 20590.
If any transit related information is needed in an alternative language, contact the Lathrop Transit Manager at 390 Towne Centre Drive, Lathrop, CA 95330, call to: 209. 941. 7220 or email to: transit( aci. lathrop. ca. us.
Fetcha
APPENDIX B: LIST OF INVESTIGATIONS, LAWSUITS AND COMPLAINTS 20 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Date Summary ( include basis of
complaint: race, color, or
national origin)
Status Action( s)
Month, Taken
Day, Year)
Investigations None None None None
Lawsuits None None None None
Complaints None None None None
21 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 APPENDIX C: SERVICE CHANGES AND OUTREACH SUMMARY
Fare and Service Changes:
Services started on April 1, 2025.
Fare free pilot for school tripper services started August 11, 2025.
Fare free pilot for school tripper services extended to June 30, 2026 on December 8, 2025.
Fare free pilot for microtransit services and school tripper services extended to June 30, 2027 on February 9, 2026.
Public Outreach:
Since April 1, 2025 the public outreach activities have occurred related to informing the community and other stakeholders about Lathrop Transit in an effort to build awareness and ridership. The City did have two workshops, one in -person and one online to gather feedback on the development of a transit system in 2024, in conjunction with San Joaquin Regional Transit District. 22 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 APPENDIX D: LIMITED ENGLISH PROFICIENCY ( LEP) PLAN
Introduction
Lathrop Transit, operated by the City of Lathrop, understands that transportation is critically important to the daily lives of our community members. The purpose of this limited English proficiency plan is to comply with Lathrop Transit' sresponsibilities to limited English proficient ( LEP) persons consistent with Title VI of the Civil Rights Act of 1964 and it' s implementing regulations. Title VI of the Civil Rights Act of 1964, 42 U. S. C. 2000d, et seq., and its implementing regulations, provides that no person shall be subjected to discrimination on the basis of race, color or national origin under any program or activity that receives federal financial assistance.
Lathrop Transit provides services to connect residents and visitors to quality -of -life opportunities.
Lathrop Transit is a direct recipient of Sections 5307 and 5339 funds in the Stockton Urbanized Area and fully implements the provisions of federal and state guidance to meet the requirements to provide public transit services. Lathrop Transit may also apply for discretionary funds via California Department of Transportation ( Caltrans) processes for Section 5310 funds.
Purpose
The purpose of this policy plan is to ensure compliance with Title VI of the Civil Rights Act of 1964.
Improving Access to Services for Persons with Limited English Proficiency," reprinted at 65 FR 50121 August 16, 2000), directs each Federal agency that is subject to the requirements of Title VI to publish guidance for its respective recipients clarifying that obligation. Different treatment based upon a person' s inability to speak, read, write, or understand English may be a type of national origin discrimination.
Applicability
All federal agencies and all programs and operations of entities that receive funding from the federal government, including state agencies, local agencies such as the City of Lathrop on behalf of Lathrop Transit, private and non- profit entities, and sub recipients.
Plan Summary
Lathrop Transit has developed this Limited English Proficiency Plan ( LEP) to help identify reasonable steps to provide language assistance for LEP persons seeking meaningful access to Lathrop Transit services as required by the FTA. A Limited English Proficiency person is one who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English.
This plan details procedures on how to identify a person who may need language assistance, the ways in which assistance may be provided, training staff, how to notify LEP persons that assistance is available, and information for future plan updates.
Definitions
Limited English Proficiency ; LEP; individual — Any prospective, potential, or actual recipient of services from Lathrop Transit who cannot speak, read, write or understand the English language at a level that permits them to interact effectively with Lathrop Transit staff. 23 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Vital Documents — Forms that include but are not limited to; applications consent forms, letters containing important information regarding participation in a program, notices pertaining to the reduction, denial, or termination of services, the right to appeal such actions, or that require a response from notices advising
LEP persons of the availability of free language assistance, and other outreach materials.
Title VI Compliance Officer — The Lathrop Transit point of contact concerning Title VI related items, who is the Deputy City Manager or his designee.
Substantial number of LEP ( Safe Harbor Threshold) — 5% or 1, 000 people, whichever is smaller, are prospective, potential or actual recipients of service and speak a primary language other than English and have Limited English Proficiency or who cannot read, write or understand the English language at a level that permits them to interact effectively with English -only speaking members of Lathrop Transit staff.
Demography
The City of Lathrop on behalf of Lathrop Transit operates transit services within its city limits, which is within the Stockton Urbanized Area. The following information is based on 2020 US Census information. See below for the service area of Lathrop Transit. The overall square miles are 21. 01 of the 92. 5square miles in the Stockton Urbanized Area. The data presented below relates to the City of Lathrop. w ..
1 r•
J1
1 24
Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 The Lathrop Transit service area ( or ride -shed) has a population of 32, 696 based on the U. S. Census Bureau, 2023 American Community Survey.
Racial Breakdown — 32% of the service area' s population is Asian, 7% is African American, 19% is White/ Caucasian, 35% is Hispanic, and Two or more races at 5%.
Spoken Language — The following data includes the Lathrop Transit service area, those persons 5 years of age or older and both Native and Foreign -born persons ( U. S. Census Bureau, 2023 American Community Survey). 53. 7% of the population speaks only English, leaving 46. 3% that can speak a language other than
English. 19% of that number is Spanish speakers. Of that population 5.9% indicate that they speak English less than " very well."
Looking only at all persons who speak English less than " very well", Spanish speakers make up the largest group at 5.9%
Household Language by Linguistic Isolation — A " limited English- speaking household" is a household in which no household member 14 years old and older (1) speaks only English or (2) speaks a non- English language and speaks English " very well." In other words, all members 14 years old and over have at least some difficulties speaking English. These residents have a particular challenge navigating American transit, and transit systems have a challenge providing a simple, no -hassle rider experience to members of these households.
Additional details on the demographics of the Lathrop Transit service area are shown below at the end of the LEP.
Action Steps
The following pages lists the details of implementing, maintaining, and monitoring Lathrop Transit' s LEP program plan to ensure federal compliance and meaningful service available to all non- English speakers using Lathrop Transit services.
Lathrop Transit will use the USDOT four factor LEP analysis to determine the LEP language groups present in the area and specific language services that are needed. The four factor analysis considers the following:
1) The number or proportion of LEP persons eligible in the Lathrop Transit service area who may be served or likely to encounter a Lathrop Transit program, activity, or service; 2) the frequency with which LEP individuals come in contact with a Lathrop Transit service; 3) the nature and importance of the program, activity or service provided by Lathrop Transit to the LEP population; and 4) the resources available to Lathrop Transit and overall costs to provide LEP assistance. A brief description of these considerations is provided in the following section.
Four Factor Analysis
1. The number or proportion of LEP persons eligible in Lathrop Transit service territory who may be served or likely to encounter a Lathrop Transit program, activity, or service.
Lathrop Transit has examined American Community Survey data table C16001 from US Census to determine the demographic makeup of the community. To get specific data related to prospective, potential, or actual recipient of services from Lathrop Transit who cannot speak, read, write or understand the English language at a level that permits them to interact effectively with agency staff, Lathrop Transit has utilized the geographic area that constitutes its service area and 0. 75 -mile buffer on all other Lathrop Transit stops. The total area covered is 21. 01 square miles with a total population of 32, 696.
25 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Based on review of the data and calculating the Safe Harbor Threshold, Lathrop Transit has identified the LEP population languages in the area as Spanish. There are over 1, 778 individuals in the Lathrop Transit service area who speak English less than very well and are fluent in Spanish.
2. The frequency with which LEP individuals come in contact with a Lathrop Transit program, activity, or service.
While we understand anecdotally that LEP persons use Lathrop Transit services, the frequency is low. This is based on the low numbers of complaints, requests, and failed communication efforts experienced by the Lathrop Transit staff.
Language Spoken at Home for Those Who Speak English Less Than ' Very Well'.
Language Of Individuals
Spanish 1, 778
French, Haitian, Cajun 10
German, West Germanic 0
Russian, Polish, Slavic 22
Other Indo- European 1,07
Korean 20
Chinese 332
Vietnamese 120
Tagalog, Filipino 889
Other Asian Pacific 663
Arabic 17
Other 16
U. S. Census Bureau, 2023 American Community Survey 1 - Year Estimates ( Table C16001) Lathrop Transit will assess the frequency at which staff, Lathrop Transit drivers, and customer service employees have or could possibly have contact with LEP persons. This includes documenting phone inquiries and verbally surveying Lathrop Transit drivers. Lathrop Transit had no requests for interpreters, and no requests for translated documents in FFY 2025.
Survey Results — Lathrop Transit completed two surveys in 2024. 115 persons completed the survey regarding the development of transit services and 97 persons completed the survey regarding provision of school tripper service. While Lathrop Transit' s ridership has consistently been predominantly white and Asian, the percentages do vary. Lathrop Transit could infer a low percentage of LEP persons currently using the system. When compared to the entire service area, ridership does not closely match the demographics of the service area. 26 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Due to the low impact from the Hispanic community, this presents a great opportunity for outreach to the LEP population. As our communities grow and interactions with LEP persons increases Lathrop Transit wishes to ensure appropriate measures are taken to communicate effectively with persons needing language assistance.
3. The nature and importance of the program, activity, or service provided by Lathrop Transit to the LEP community.
Lathrop Transit understands that transportation is critically important to the daily lives of our community members. Certain aspects of our services are of critical importance and this plan will be used to meet the needs of the LEP community. Lathrop Transit provides important transportation services to the public throughout its service area. Lathrop Transit connects the major cities and towns of the Lathrop - Graham Urbanized Area to quality -of -life opportunities. Lathrop Transit also provides services to connect to Amtrak station in Lathrop. Lathrop Transit riders utilize services to commute to work, going to school/ universities, occasionally for special events and also in lieu of reliance on a personal automobile.
4. The resources available to Lathrop Transit and costs.
Lathrop Transit has identified in- house staff with language abilities apart from English, and this staff has some availability to assist with requests related to Lathrop Transit services, including transit. This is the case with the City of Lathrop and the Lathrop Transit contractor staff. Lathrop Transit has also identified some businesses and technological solutions that provide translation and interpretative services, these services would be utilized on as needed basis. To make public meetings available to LEP persons, volunteer translators are available through University of North Carolina - Greensboro UNCG). This resource could also be used to provide translation for written materials in Spanish or other languages. Details on this program is here: https:// cnnc. unq. edu/ interpreter- access- project/ Lathrop Transit website has the capability to translate all the information to multiple languages including Spanish through Google Translate.
Lathrop Transit used Language Line as an opportunity to provide additional verbal translation assistance to Lathrop Transit staff with the ability to translate over 135 different languages.
Based on the Four Factor Analysis, Lathrop Transit determined to have a Language Assistance Plan for the Spanish Population.
27 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Input Census Data from UZA Here)
Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 29 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 30 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 31 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028
LANGUAGE ASSISTANCE PLAN
Implementation Methods
How to Identify an LEP Person who Needs Language Assistance — These methods may be used to help identify persons who may need language assistance:
1. Communicate and coordinate with the San Joaquin Council of Governments.
2. Examine records requests for language assistance from past meetings and events to anticipate the possible need for assistance at upcoming meetings.
3. When public meetings are held, have a staff member greet and briefly speak to each attendee. To informally gauge the attendee' sability to speak and understand English, ask a question that requires a full sentence reply.
Language Assistance Measures - Lathrop Transit may implement the following LEP procedures as appropriate:
1. Lathrop Transit has identified in- house staff with other language abilities and this staff has some availability to assist with requests related to Lathrop Transit services, including transit.
2. Public notice, publications, and other material, including webpage content, may be made available in other languages.
3. Utilize translators at select public meetings; and
4. Use a
telephone translation service such as Language Line, and web translation applications such as Google Translate.
Training — Lathrop Transit implements training for Lathrop Transit front- line contracted employees on Title VI and LEP considerations through the contractor. These training opportunities occur on planned schedules and include opportunities for virtual training seminars provided from the video session from LEP. gov. Front- line employees or contractors who come in contact with LEP individuals are Bus Operators, Customer Service Representatives and Road Supervisors. LEP training include understanding Title VI responsibilities, what procedures to follow when encountering an LEP person and how to potentially handle a Title VI complaint.
Outreach — Specific outreach efforts will be evaluated on a case -by -case basis. Some or all the following methods may be used:
1. Posters and brochures will be made available through City Hall and other locations.
2. Lathrop Transit website will indicate ways in which LEP persons can access information about our services.
3. The Lathrop Transit Notice of Rights under Title VI to the public is available at the Lathrop Transit office, on buses, online at www. lathroptransit. com, and within the Ride Guide.
4. If staff knows that they will be presenting a topic that could be of importance to an LEP individual or if staff will be hosting a meeting or a workshop in a geographic location with a known concentration of LEP persons, meeting notices, fliers, advertisements, and agendas will be available in an alternative language, based on known LEP population in the area.
Monitoring, Evaluating and Updating the LEP & LAP Plans This plan is designed to be flexible and is one that can be easily updated. At a minimum, Lathrop Transit will follow the Title VI Program update schedule for the LEP plan. Future plan updates will include the most current data available. The results may change based on the timing of the plan update. 32 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028 Each update will examine all plan components such as:
1. How many LEP persons were encountered?
2. Were their needs met?
3. What is the current LEP population in Lathrop Transit service area?
4. Has there been a change in the types of languages where translation services are needed?
5. Is there still a need for continued language assistance for any previously identified Lathrop Transit programs? Are there other programs that should be included?
6. Have Lathrop Transit' s available resources, such as technology, staff, and financial costs changed?
7. Has Lathrop Transit fulfilled the goals of the LEP Plan?
8. Were any complaints received?
Dissemination of the LEP & LAP Plans
Copies of the LEP plan will be on file at the Lathrop Transit office. The LEP plan will be provided, on request, to any person( s) requesting the document via phone, in person, by mail or email. LEP persons may obtain copies/ translations of the plan upon request. The plan will also be available on the Lathrop Transit website.
Any questions or comments regarding this plan should be directed to the City of Lathrop, Attn: Title VI Complaints, 390 Towne Centre Drive, Lathrop, CA 95330, or email to: transit( ci. lathrop. ca. us. 33 Lathrop Transit Title VI Program for Federal Fiscal Year 2025-028