City of Richmond
Department of Public Works
450 Civic Center Plaza
Richmond, CA 94804
DocID #73170v1
PUBLIC WORKS DEPARTMENT
TITLE VI PLAN
June 16, 2026
Plan Scope
This document is the City of Richmond Public Works Department (“Department”) Title VI Program Plan, adopted to satisfy Caltrans Local Assistance Program (LAP) requirements for federal-aid transportation projects administered by the Department. As such, the plan governs non-discrimination obligations arising from Public Works Department activities and programs funded by the Federal Highway Administration (FHWA), an agency within the Department of Transportation.
The Public Works Director designates the Public Works Title VI Coordinator to lead compliance for all FHWA-funded projects.
Title VI Compliance Statement
The Department is a recipient of federal funding and, therefore, is required to comply with Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq). This legislation mandates that all services and benefits provided by the Department must be offered on a nondiscriminatory basis. This policy applies to all operations of the City of Richmond Public Works Department, including its contractors and any individuals or entities acting on the Department’s behalf. It also applies to any sub -recipient that receives federal financial assistance through the Department. Federal financial assistance may include grants, training, equipment, surplus property donations, or other forms of support.
Prohibited discrimination can be intentional or unintentional. Neutr al actions that disproportionately impact members of a protected group, without substantial and legitimate justification, are considered discriminatory. Harassment and retaliation are also prohibited.
Examples of prohibited discrimination based on race, color, national origin, sex, disability, age, or other protected status include:
Denying an individual access to any service, financial aid, or benefit. Providing benefits that differ in quality, quantity, or manner of delivery. Segregating or otherwise treating individuals separately. Restricting access to advantages, privileges, or other benefits. Discriminating in any highway, infrastructure, or facility-related activities; and Discrimination in employment practices.
Title VI compliance is a condition of receiving federal funds. The Title VI Coordinator, along with designated City staff, is authorized to ensure compliance with this policy, Title VI of the Civil Rights Act of 1964 and related statutes and regulations.
Public Works Director Date
1. Title VI Related Authorities
Title VI of the Civil Rights Act of 1964 prohibits discrimination based on race, color, or national origin in any program or activity receiving federal financial assistance. Under 49 CFR Part 21, no person in the United States may be excluded from participation in, denied the benefits of, or otherwise subjected to discrimination in programs or activities receiving Federal financial assistance from the Department of Transportation, including the Federal Highway Administration.
Section 162(a) of the Federal -Aid Highway Act of 1973 (23 U.S.C. § 324 ) prohibits discrimination on the basis of sex by recipients and sub- recipients of Federal financial assistance.
Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 794) prohibits discrimination on the basis of disability by recipients and sub-recipients of federal financial assistance. The Age Discrimination Act of 1975 (42 U.S.C. § 6101 et seq.) prohibits discrimination on the basis of age by recipients and sub-recipients of federal financial assistance.
The Civil Rights Restoration Act of 1987 (Public Law 100- 259) 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 statues 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 on February 11, 1994, focuses on Environmental Justice for minority and low-income populations. It requires federal agencies to develop strategies to address disproportionately high and adverse health or environmental impacts of their programs on these communities, ensure nondiscrimination in programs that significantly affect human health and the environment, and provide affected populations with access to public information and opportunities for participation in related decision-making.
Executive Order 13166, issued on August 16, 2000, requires agencies to improve access to services for individuals with limited English proficiency (LEP). Agencies must review the services they provide and establish systems that ensure LEP individuals can meaningfully access those services without compromising the agency’s core mission. In addition, agencies must ensure that recipients of federal financial assistance provide LEP applicants and beneficiaries with free, meaningful access to programs, services, and information.
2. Organization, Staffing, and Responsibilities for Title VI Compliance
The City of Richmond Public Works Department Title VI Coordinator is responsible for overall program implementation of Title VI and performs a lead role in developing and administering Title VI compliance for FHWA-funded transportation programs. The Title VI Coordinator reports to the Public Works Director.
Designation of Title VI Coordinator
In compliance with Title VI of the Civil Rights Act of 1964 and related statutes and regulations, I hereby designate the following individual as the City of Richmond Public Works Department Title VI Coordinator:
Hillal Hamdan
Senior Civil Engineer
Title VI Coordinator, City of Richmond Public Works Department 450 Civic Center Plaza, Richmond, CA 94804
(510) 621-1612 | [email protected]
The Title VI Coordinator is a Senior Civil Engineer within the Public Works Administration & Engineering Division. This position has authority to require compliance by departmental staff and contractors on all FHWA-funded projects and serves as the primary contact with Caltrans and FHWA on Title VI matters.
Reporting Structure
The Title VI Coordinator reports directly to the Public Works Director.
Backup Coordinator
To be designated by the Public Works Director. The backup coordinator must complete Title VI training within 90 days of designation and is authorized to act in all capacities of the Title VI Coordinator during periods of absence.
Core Responsibilities of the Title VI Coordinator
The Title VI Coordinator manages the Public Works Department’s Title VI Program, acting as the primary compliance and coordination body with direct access to the City Manager and Department Directors. The Title VI coordinator’s main duties include:
• Reporting: Submitting the official Title VI plan and annual compliance reports to relevant agencies.
• Complaint Management: Developing clear procedures for the prompt processing and resolution of discrimination complaints.
Leading investigations, documenting resolutions, and reporting complaints to state and federal agencies as required.
• Program Development & Review:
o Coordinating with Department Directors to develop procedures for collecting and analyzing statistical data.
o Establishing a program to conduct annual Title VI assessments and reviews across all pertinent program areas.
• Training & Outreach:
o Participating in the design and distribution of Title VI information to the public.
o Supporting the development and implementation of Title VI training for City management, supervisors, and staff.
• Contractual Assurance: Establishing procedures to ensure that all Federal-aid Contracts and Agreements include Title VI Assurances.
• Deficiency Resolution: Establishing procedures to resolve any compliance deficiencies and document necessary remedial actions.
Departmental Responsibilities
This plan governs Public Works Department activities as they relate to FHWA-funded programs. • Human Resources: coordinates with the Title VI Coordinator on employment-related non- discrimination requirements under FHWA-funded programs. • Public Works: implements Title VI as it relates to consultants, contractors, and FHWA- funded infrastructure activities.
3. Federal-Aid Title VI Implementation
A. Public Participation and Outreach
The City of Richmond Public Works Department will develop and disseminate a Title VI information webpage informing the public that the Department administers programs subject to the nondiscrimination requirements of Title VI and related statutes and regulations.
Upon request from persons served by or participating in federal-aid programs administered by the Department, the Department will provide sign language interpreters, oral interpretation in any language upon request, and make information available in alternate formats.
Public Participation Plan
To ensure meaningful and equitable public participation in federally funded programs and projects, the Department will:
• Use outreach methods accessible to all community members, including flyers, social media, multilingual notices, and in-person meetings held at accessible locations. • Provide written translation of vital documents in Spanish and Chinese (the primary LEP languages in Richmond) and in additional languages upon request.
• Actively engage community-based organizations serving minority, low-income, and LEP populations.
• Ensure meeting locations and facilities are ADA-accessible. • Document all public outreach efforts, including attendance, languages used, and community feedback received.
• Evaluate the effectiveness of outreach by tracking participation demographics and comparing them to community demographics.
B. Limited English Proficiency (LEP) Plan
Table: English Proficiency by Language Spoken at Home for Richmond’s Residents Source: U.S. Census Bureau. "Language Spoken at Home for the Population 5 Years and Over." American Community Survey, ACS 5-Year Estimates Detailed Tables, Table C16001, 2022
Limited English Proficiency (LEP) Requirements and Local Context Individuals with Limited English Proficiency (LEP) are those who do not use English as their primary language and have restricted capabilities in reading, writing, or comprehending English.
Federal Mandate:
Executive Order 13166 requires all federally funded agencies to evaluate their services and develop procedures that guarantee LEP individuals meaningful access to those services. The Order specifically requires establishing access guidance, preparing plans to mitigate language barriers, and soliciting input from relevant stakeholders.
City of Richmond Data and Compliance:
According to the data provided, 19% of Richmond residents are categorized as LEP.
The most prevalent language spoken by this group is Spanish (13.3% of the total community), with Other Asian and Pacific Island Languages representing the next largest share (1.1%).
C. In accordance with Executive Order 13166, the Department will ensure that LEP persons served by FHWA-funded programs are provided, free of charge, meaningful access to programs, services, and information. The full LEP Plan is included as Attachment D.
The Department applied the Department of Transportation’s Four-Factor Analysis to determine the level of language services required:
1. Number/proportion of LEP persons: Approximately 19% of Richmond residents are LEP. Spanish is the primary LEP language (13.3% of the total population), followed by Other Asian and Pacific Island languages (1.1%). See Attachment D Table 1 for full language demographic data.
2. Frequency of contact: Public Works staff regularly interface with residents during construction projects, permit activities, and public outreach. LEP contact is anticipated frequently given Richmond's demographics.
3. Importance of the program: Access to transportation infrastructure, construction impact information, and public participation opportunities is material to residents' quality of life and safety. Denial or delay of access could have significant adverse effects on LEP individuals.
4. Resources and costs: The Department will provide interpretation and translation services through a combination of bilingual staff, contracted language services, and the Language Line Solutions telephone interpretation service. Costs will be allocated to the program responsible for the information being requested.
Based on this analysis, the Department will:
• Provide vital documents in Spanish and Chinese at minimum. • Provide oral interpretation services upon request in any language. • Distribute the Census Bureau iSpeak Language Identification Card to all staff with potential public contact.
• Maintain an account with Language Line Solutions for telephone interpretation (dial 1-866-874-3972; Customer ID available from the Title VI Coordinator). • Provide Relay California (dial 711) access information for persons who are deaf, hard of hearing, or speech-disabled.
C. Environmental Justice in Minority and Low-Income Populations
In compliance with Executive Order 12898, the Department will conduct project-level environmental justice analysis for federally funded projects. This analysis will include:
• Demographic mapping of the project area using U.S. Census data. • Identification of minority and low-income populations within and adjacent to the project area.
• Assessment of whether the project presents disproportionately high and adverse effects on those populations.
• Development of mitigation measures where adverse impacts are identified. • Meaningful public participation opportunities for affected communities during project planning and design.
This is particularly important for transportation and infrastructure projects in communities such as the Iron Triangle, Santa Fe, and Coronado neighborhoods.
D. Site and Facility Location
The Department will not select a site or location for any facility in a manner that intentionally excludes individuals from participation in, or denies them the benefits of, federal-aid programs on the grounds of race, color, or national origin, or that would substantially impair nondiscrimination objectives.
E. Title VI Assurances in Contracts and Agreements
The Department will incorporate Title VI assurances in all Master and Supplemental Agreements with Caltrans for each project, including the Department's reaffirmation of nondiscrimination assurances.
All federal-aid contracts and agreements will include the standard FHWA Title VI contract provisions as specified in Appendix A of the Administering Agency-State Agreement for Federal-Aid Projects (LAPM). This includes:
• Standard FHWA Title VI contract clauses prohibiting discrimination. • Contractor obligations to monitor sub-contractors for compliance. • Requirement for contractors to submit corrective action plans upon identification of non-compliance.
• Termination remedies for material non-compliance with Title VI provisions.
The Title VI Coordinator, in coordination with the relevant project manager, will review all federal-aid contracts prior to execution to confirm that Title VI assurances are included.
F. Notice of Rights
The City of Richmond will publicly post its "Notice of Rights" (found in Attachment A) at various City facilities and customer service areas.
This notice confirms the City's commitment to Title VI compliance, ensuring that no individual will face exclusion, benefit denial, or discrimination in any City programs, activities, or services based on race, color, national origin, sex, disability, age, or other protected status.
The notice will be initially available in English, Chinese, and Spanish. Other languages and formats will be provided upon request. Title VI-related materials are also accessible online at https://www.ci.richmond.ca.us/.
G. Data Collection
The Department is dedicated to continuously improving its data collection and analysis methods to enhance the Plan's effectiveness.
• The Department collects and analyzes data specific to its FHWA-funded programs and services.
• This data helps the Department understand the needs and characteristics of the communities it serves through FHWA-funded programs, which allows it to tailor services, deliver effective and equitable results, and ensure meaningful access to all information and activities.
• The Department is responsible for reviewing its data collection and outreach procedures related to FHWA-funded programs to ensure they are effective.
Data Sources
Demographic and related data used by staff for accuracy and consistency is drawn from reliable governmental sources. These sources include, but are not limited to:
• U.S. Census Bureau
• U.S. Bureau of Labor Statistics
• U.S. Bureau of Economic Analysis
• California Department of Finance
• California Department of Labor/Employment Development Department • Association of Bay Area Governments (ABAG)
• Metropolitan Transportation Commission (MTC)
For FHWA-funded projects administered by the Department, Public Works staff will use various methods during public outreach to collect project-specific demographic data.
These methods may include surveys, social media releases, public meetings, and public comments collected via project websites.
4. Title VI Outreach and Resources
A. Training and Documentation
The Department will provide Title VI training differentiated by role as follows:
Staff Group Training Frequency
Title VI Coordinator Annual
Managers and Supervisors Every 2 years
Public-facing staff Every 2 years
New employees Within 90 days of hire
Training will cover: the City's Title VI Implementation Plan and related documents; language assistance services available to the public; complaint and reporting procedures; and guidance on obtaining help for Title VI questions.
The Title VI Coordinator will tailor training for specific program areas where the annual assessment reveals gaps in understanding. Links to Title VI resources from Caltrans, FHWA, and other relevant agencies will be posted on the City's Title VI webpage.
B. Contract Documents and Agreements
Title VI Coordinator, in coordination with Department Directors or their Liaisons, must ensure that all contracts and agreements for federally funded projects include:
• The Department shall ensure that all applicable provisions listed in Appendix A of Exhibit B of the Administering Agency–State Agreement for Federal-Aid Projects Master Agreement (LAPM) are included in contracts and agreements with contractors. Other applicable non-discrimination provisions and forms.
B. Annual Planning and Compliance
i. Program Assessment and Annual Monitoring
The Department will conduct an annual assessment of all public participation/outreach and programmatic activity areas in relation to major federal -aid programs to determine effectiveness in ensuring nondiscrimination. The annual assessment will review:
• Federally funded contracts for Title VI assurance compliance. • Procurement activities for nondiscrimination.
• Public outreach efforts and participation demographics. • Complaint logs and resolution outcomes.
• Language access requests and response effectiveness.
• Training completion rates by staff group.
If Title VI compliance issues are identified, they will be addressed by immediate corrective action and/or revision to the Title VI Plan as appropriate.
Annual Work Plan and Goals and Accomplishments Report
The Title VI Coordinator will annually establish program goals and maintain a Work Plan to guide compliance. The following table establishes the minimum annual goals:
Goal Action Responsible
Party
Due Date
Update LEP
demographic data
Review ACS/Census data;
revise translation
thresholds
Title VI Coordinator Annually (January)
Conduct Title VI training Schedule and document
all required training
Public Works Per training schedule
Review federal-aid
contracts
Confirm Title VI
assurances in all active
contracts
Public Works Quarterly
Review and report
complaints
Update complaint log;
prepare annual report
section
Title VI Coordinator Annually
Update public notices Refresh posted notices
and website content
Title VI Coordinator Annually
Complete program area
review
Assess each
programmatic activity area
Title VI Coordinator Annually (Q4)
The annual Goals and Accomplishments Report is a mandatory document required by FHWA. It will document: updates to the Title VI Program, internal program area reviews, training conducted, and complaint processing outcomes.
ii. Compliance and Enforcement
The City of Richmond is committed to monitoring, reviewing, and reporting on Title VI compliance.
• Notification of Violations: If the City determines, after review (desk audit, compliance review, or complaint investigation), that a sub-recipient (e.g., contractors, vendors) or City employee is non-compliant, they will be notified in writing of the violation(s) and recommended corrective actions.
• Corrective Action: Non-compliant parties are expected to implement corrective actions within a reasonable period. The Title VI Coordinator will assist to ensure the violations are sufficiently corrected.
iii. Legal Oversight of Policy
The City Attorney shall provide legal guidance regarding Title VI compliance issues as requested by the Title VI Coordinator or the Public Works Director.
5. Title VI Complaints Processed Under the Federal Highway Administration (FHWA)
Per the FHWA Guidance Memorandum, Processing of Title VI Complaints , dated June 13, 2018, all Title VI complaints received by the City 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 [email protected] . If Headquarters Office of Civil Rights (HCR) determines a Title VI complaint against the City can be investigated by Caltrans, HCR may delegate the task of investigating the complaint to Caltrans.
Please refer to the Caltrans Office of Civil Rights website for further information regarding filing a Title VI complaint. Please direct these requests to the Department’s Title VI Coordinator. The full complaint procedure and complaint form are outlined in Attachment B. Spanish and Chinese versions of the complaint procedure and complaint form are available upon request. Versions in other languages are also available upon request.
Attachment A - Notice of Rights
ATTACHMENT B
Discrimination Complaint Procedure
Federal law prohibits discrimination on the basis of race, color, national origin, age, sex, or disability in any Richmond Public Works Department program or activity.
This prohibition applies to all branches of the City of Richmond Public Works Department, its contractors, consultants, and anyone else who acts on behalf of the City of Richmond Public Works Department.
Federal law requires that the City of Richmond Public Works Department investigate, track, and report discrimination complaints. Complaints must be filed in writing and will be investigated within sixty days of submission. If you need assistance to file your complaint or need interpretation services, please contact:
Hillal Hamdan
Senior Civil Engineer
Title VI Coordinator
510-621-1612
[email protected]
Who is eligible to file a complaint?
Anyone who believes they have been excluded from participation in, denied the benefits of, or otherwise subjected to discrimination under any City of Richmond Public Works Department program or activity because of their race, color, national origin, age, s ex, or disability may file a complaint.
Discrimination includes lack of access, harassment, retaliation and disparate impacts from a program or activity. Harassment includes a wide range of abusive and humiliating verbal or physical behaviors. Retaliation includes intimidating, threatening, coercing, or engaging in other discriminatory conduct against anyone because they filed a complaint or otherwise participated in a discrimination investigation.
How do you file a complaint?
Complaints must be filed in writing within 180 days from the last date of the alleged discrimination.
However, contact Hillal Hamdan, Title VI Coordinator, if you believe your complaint may fall outside this deadline.
Reasonable efforts will be made to assist persons with disabilities, non-English speakers, and others unable to file a written complaint.
Complaints may be submitted via mail, email, fax, or in person to:
Hillal Hamdan
Senior Civil Engineer
Title VI Coordinator
510-621-1612
[email protected]
What happens after a complaint is filed?
Title VI complaints must be investigated within sixty (60) days. Investigating a complaint includes interviewing all parties involved and key witnesses. The investigator may also request relevant information such as books, records, electronic information, and other sources of information from all involved parties. You may specify if there is a particular individual or individuals that you feel should not investigate your complaint due to conflict of interest or other reasons.
In some cases, complaints will be forwarded to the Federal Highway Administration for investigation. If your complaint is forwarded to one of these agencies, you will be provided the name and contact information of the employee handling your complaint.
Federal law prohibits retaliation against individuals because they have filed a discrimination complaint or otherwise participated in a discrimination investigation. Any alleged retaliation should be reported in writing to the investigator.
ATTACHMENT C
ATTACHMENT D
City of Richmond Public Works Department LEP Plan — Attachment C June 2026 Page 1
DocID #73199v1
City of Richmond
Department of Public Works
450 Civic Center Plaza, Richmond, CA 94804
LIMITED ENGLISH PROFICIENCY (LEP) PLAN
Attachment C to the Title VI Implementation Plan
June 2026
City of Richmond Public Works Department LEP Plan — Attachment C June 2026 Page 2
DocID #73199v1
Introduction
Executive Order 13166 (August 11, 2000), "Improving Access to Services for Persons with Limited English Proficiency," requires federal agencies, including the U.S.
Department of Transportation (USDOT), to implement measures to ensure that individuals having a limited ability to read, write, speak, or understand English have meaningful access to programs and activities that are conducted or funded by the federal government, consistent with Title VI of the Civil Rights Act of 1964. These individuals are entitled to language assistance with respect to particular services, benefits, or encounters.
The City of Richmond Public Works Department (“Department”) is a recipient of federal funds from the U.S. Department of Transportation (USDOT) via the Federal Highway Administration (FHWA) for transportation infrastructure projects. Pursuant to Executive Order 13166, USDOT published guidelines on December 14, 2005 entitled “Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficient (LEP) persons” (70 FR 74087). The USDOT guidance requires recipients of USDOT funding to take reasonable steps to ensure that LEP individuals have meaningful access to all programs and activities of the recipient.
In accordance with the USDOT guidance, this LEP Plan identifies the language needs of the LEP populations that the Department serves and what language assistance measures are sufficient to ensure meaningful access to the Department’s programs or activities.
.
______________________________________________ ____________________ Daniel Chavarria, P.E., Public Works Director Date
Elements of an Effective LEP Plan
The U.S. Department of Justice, Civil Rights Division, has identified key elements for designing an effective LEP plan. The following elements have been incorporated into this plan:
• Identifying LEP persons who need language assistance
• Identifying ways in which language assistance will be provided • Training staff on language access protocols
• Providing notice to LEP persons of available free services • Applying the USDOT Four-Factor Analysis to determine the level of service required
• Evaluating and updating the plan periodically
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Four-Factor Analysis
The USDOT guidance requires recipients to apply a four-factor analysis to assess language needs and determine the reasonable steps necessary to ensure meaningful access for LEP persons. The four factors are:
• Factor 1: The number or proportion of LEP persons likely to be encountered by the program, activity, or service.
• Factor 2: The frequency with which LEP individuals come into contact with the program.
• Factor 3: The nature and importance of the program, activity, or service to the LEP community.
• Factor 4: The resources available to the Department and the overall cost of language assistance.
The greater the number or proportion of eligible LEP persons, the more frequently they contact a program, and the greater the importance of that program, the more enhanced language services will be needed. The DOT guidance intends to ensure meaningful access without imposing undue burdens on local agencies.
Factor 1: Number and Proportion of LEP Persons
According to the U.S. Census Bureau American Community Survey (ACS), 5-Year Estimates, Table C16001, 2022, approximately 19% of Richmond residents aged 5 and over are Limited English Proficient — meaning they speak English less than "very well." This is substantially higher than the national average of 8.4%.
The primary LEP language group is Spanish (13.3% of total population), which clearly exceeds the Safe Harbor threshold of 5% or 1,000 persons, whichever is less. Chinese (including Mandarin and Cantonese) approaches the 1,000-person threshold. The table below summarizes Richmond's language demographic profile.
Table 1. Language Demographic Profile — City of Richmond Source: U.S. Census Bureau, American Community Survey, ACS 5-Year Estimates, Table C16001, 2022 Language Group Total
Speakers
Speak
English
"Very Well"
Speak English
Less Than "Very
Well" (LEP)
% of Total
Pop. 5+
Speak only English 63,200 — — 61.0%
Spanish 22,900 9,700 13,200 13.3% ✓
Safe
Harbor
Portuguese /
Brazilian
1,050 620 430 0.4%
Russian / Slavic 640 370 270 0.3%
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Language Group Total
Speakers
Speak
English
"Very Well"
Speak English
Less Than "Very
Well" (LEP)
% of Total
Pop. 5+
Other Indo-
European
1,800 1,020 780 0.8%
Chinese (incl.
Mandarin,
Cantonese)
2,050 1,170 880 0.9%
Vietnamese 960 440 520 0.5%
Tagalog (incl.
Filipino)
1,620 1,100 520 0.5%
Other Asian &
Pacific Island
1,160 640 520 0.5%
Other and
unspecified
1,470 900 570 0.6%
TOTAL
POPULATION 5+
103,700 — ~19,700 ~19.0%
Note: Estimates are subject to sampling error. Figures represent the Richmond city boundary. Total population 5+ is approximately 103,700. Percentages are rounded to one decimal place.
Safe Harbor Threshold Analysis
Federal guidance provides a "Safe Harbor" provision: recipients that provide written translations of vital documents for each eligible LEP language group constituting 5% or 1,000 persons (whichever is less) of the population served will be considered in strong compliance with written translation obligations. Oral translation does not create this safe harbor.
Table 2. Safe Harbor Analysis
Language LEP Population
(est.)
Safe Harbor Status
Spanish ~13,200 (13.3% of
pop. 5+)
✓ EXCEEDS threshold — mandatory
written translation
Chinese (all
dialects)
~880 (0.9% of pop.
5+)
Below 5% but approaches 1,000 —
translation strongly recommended
Vietnamese ~520 (0.5% of pop.
5+)
Below threshold — oral interpretation on
request
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Language LEP Population
(est.)
Safe Harbor Status
All other
languages
< 500 each Below threshold — oral interpretation on
request
Based on this analysis, Spanish written translation is mandatory. Chinese translation is strongly recommended given the absolute population and the demographic trajectory of the Iron Triangle, Santa Fe, and Coronado neighborhoods served by FHWA-funded projects.
Factor 2: Frequency of Contact with LEP Individuals
Public Works staff interface regularly with the public in several contexts that generate frequent contact with LEP individuals:
• Construction project outreach: Active construction projects in residential neighborhoods — including the Neighborhood Complete Streets initiative in the Iron Triangle, Santa Fe, and Coronado areas — require direct resident communication about impacts, detours, and schedules. These neighborhoods have among the highest LEP concentrations in the City.
• Permit and development activities: The permit counter at 450 Civic Center Plaza is accessible to the public and routinely serves Spanish-speaking residents seeking encroachment permits, utility connections, and construction inspections. • Public meetings and hearings: Federally funded transportation and infrastructure projects require public engagement that draws community members from across Richmond's diverse population.
• Field operations: Field crews encounter residents during construction activities, utility work, and emergency responses in residential areas with high Spanish- speaking populations.
• Complaint and inquiry intake: Residents contact the Department by phone, email, and in person with service requests, concerns, and complaints.
Given that approximately 19% of Richmond residents are LEP individuals — with Spanish speakers constituting 13.3% of the total population — frequent LEP contact is expected across all Public Works program areas. Contact is particularly high in connection with FHWA-funded active transportation and infrastructure projects in west and central Richmond.
Factor 3: Nature and Importance of the Program
The Public Works Department is responsible for constructing and maintaining transportation infrastructure, processing permits, managing active construction projects in residential neighborhoods, and conducting public outreach on projects that directly affect residents' quality of life, safety, and mobility.
The consequences of inadequate language access are concrete and serious:
• Safety: LEP residents who cannot access construction detour information, road closure notices, or emergency access information may be placed at physical risk.
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• Civic participation: Public meetings on federally funded projects that are not accessible to LEP residents effectively exclude a significant portion of the affected community from decision-making, potentially violating Title VI requirements for meaningful participation.
• Economic access: LEP small business owners and property owners affected by construction projects who cannot communicate with the Department about impacts, timelines, or mitigation cannot effectively protect their interests. • Complaint access: LEP residents who cannot file complaints or access the Department's dispute resolution processes are denied a fundamental protection.
The Iron Triangle, Santa Fe, and Coronado neighborhoods — which are the primary service areas for several active FHWA-funded projects including the Neighborhood Complete Streets initiative — have some of the highest concentrations of Spanish- speaking and LEP residents in Contra Costa County. Language access in these programs is therefore of heightened importance.
Factor 4: Resources Available and Overall Cost
The Department will provide language services through a tiered, cost-effective approach:
• Bilingual staff (first resort): Where bilingual staff are available, they will be used as the primary resource for oral interpretation. Staff are not required to serve as interpreters for complex technical or legal matters.
• Language Line Solutions (standing telephone interpretation service): The Department maintains an account with Language Line Solutions for telephone interpretation in any language. Staff dial 1-866-874-3972, provide the Customer ID (available from the Title VI Coordinator), request the needed language, and document the interpreter name and ID.
• Written translation: Vital documents in Spanish will be translated in-house or through contracted translation services. Chinese translation will be obtained for project-level communications in areas with significant Chinese-speaking populations. Costs will be allocated to the responsible program on an as-needed basis.
• Relay California (dial 711): Provides full telephone access to persons who are deaf, hard-of-hearing, deaf-blind, or speech-disabled, free of charge.
Although no fixed annual budget line is established for translation, the cost of complying with LEP requirements is expected to be modest relative to overall project budgets and will be allocated to the program responsible for the information being requested. The Department will not limit language services due to cost concerns where denial of access would constitute a Title VI violation.
Language Assistance Measures
Vital Documents — Written Translation
The following documents are designated as "vital" and will be translated into Spanish at minimum, and into Chinese for project areas with significant Chinese-speaking populations:
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• Public notices for federally funded projects (construction notices, detour notices, public meeting notices)
• Title VI Non-Discrimination Notice (Attachment A to the Title VI Plan) • Discrimination Complaint Procedure and Complaint Form (Attachment B to the Title VI Plan)
• Project-specific outreach materials, fact sheets, and surveys • Any written communication that may deny or limit access to a Department service or benefit
Other documents may be provided in translation orally upon request. The Title VI Coordinator maintains a list of vital documents and tracks translation status.
Oral Interpretation
The Department will provide oral interpretation services upon request in any language, free of charge. Staff will follow the LEP Staff Reference Card (Appendix B) to identify resources. The standard protocol is:
• Step 1: Identify the person's language using the Census Bureau iSpeak Language Identification Card (Appendix A).
• Step 2: If bilingual staff are available, use them as a first resource. • Step 3: If bilingual staff are not available, contact Language Line Solutions: dial 1-866-874-3972, provide the Customer ID (available from the Title VI Coordinator), and request the required language. Document the interpreter name and ID number.
• Step 4: For written translation requests, contact the Title VI Coordinator to arrange services.
• Step 5: Document all language access requests in the Title VI Coordinator's log.
Notice to LEP Persons
The Department will notify LEP persons of available free language services through:
• Signage in Spanish (and other languages as needed) at public-facing office locations and active construction project areas.
• Outreach documents and project fact sheets stating that free language services are available, with the Department's contact information. • The Title VI Non-Discrimination Notice (Attachment A), available in English, Spanish, and Chinese.
• Coordination with community-based organizations — including Iron Triangle Neighborhood Council, Richmond Community Foundation, and Latina Center — to distribute information about available language services. • The City's website (https://www.ci.richmond.ca.us/) with Title VI information and contact information for language assistance requests.
Staff Training on Language Access
The Title VI Coordinator will ensure that Department staff receive training on LEP procedures according to the following schedule:
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Table 3. Training Schedule
Staff Group Training Frequency
Title VI Coordinator Annual
Managers and Supervisors Every 2 years
Public-facing and field staff Every 2 years
New employees Within 90 days of hire
Training will cover: the iSpeak Language Identification Card; the LEP Staff Reference Card; Language Line Solutions procedures; vital document translation protocols; how to document and report language access requests; and how to escalate complex situations to the Title VI Coordinator.
Training materials will be available on the Department's internal intranet. Links to USDOT, FHWA, and Caltrans LEP resources will be posted on the City's Title VI webpage.
Appendices
Appendix A: Census Bureau iSpeak Language Identification Card (2020 edition) Appendix B: LEP Staff Reference Card — Interpretation & Translation Resources
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APPENDIX A
Census Bureau iSpeak Language Identification Card
The iSpeak card is a multilingual card that helps staff identify what language a person speaks. It shows phrases in 38 languages asking the person to point to the name of the language they speak.
The card should be distributed to all staff with potential public contact, including permit counter staff, field crews, inspection staff, and anyone conducting public outreach.
The 2020 Census Bureau iSpeak Language Identification Card is available for free download at: https://www.census.gov/library/visualizations/2020/comm/ispeak.html Printed copies are maintained at the Title VI Coordinator's office at 450 Civic Center Plaza. Contact Hillal Hamdan, (510) 621-1612, to obtain copies.
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APPENDIX B
LEP Staff Reference Card
Interpretation & Translation Services — City of Richmond Public Works Department
The City of Richmond Public Works Department provides reasonable language assistance free of charge upon request. Use the steps below when a person requests language assistance.
Step 1 — Identify the language
Use the iSpeak Language Identification Card (Appendix A). Show the card to the person and ask them to point to the name of their language.
Step 2 — Use bilingual staff (first resort)
If bilingual staff are available, use them as the first resource. Check with your supervisor or the permit counter for available bilingual staff. Do not ask a minor or a member of the public to interpret.
Step 3 — Language Line Solutions (if bilingual staff unavailable) Language Line Solutions provides telephone interpretation in over 240 languages, 24 hours a day, 7 days a week.
Step Action
Dial 1-866-874-3972
Provide Customer
ID
Available from the Title VI Coordinator — Hillal Hamdan, (510) 621-1612
Request language State the language needed, e.g., "Spanish," "Vietnamese," "Cantonese"
Brief the interpreter Explain the situation briefly and give any special instructions Document Record the interpreter's name and ID number in the language access log
Step 4 — Written translation requests
For requests to translate written documents, contact the Title VI Coordinator to arrange translation services. Do not use machine translation (e.g., Google Translate) for vital documents without coordinator approval.
Step 5 — Deaf, hard-of-hearing, or speech-disabled persons City of Richmond Public Works Department LEP Plan — Attachment C June 2026 Page 11
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Dial 711 to reach Relay California. This is a free service that provides full telephone access to people who are deaf, hard of hearing, deaf-blind, or speech-disabled.
Step 6 — Document and report
Log all language access requests in the Title VI Coordinator's language access log, including: date, language needed, method used, and outcome. Submit logs to the Title VI Coordinator quarterly.
Title VI Coordinator Contact:
Hillal Hamdan, Senior Civil Engineer
City of Richmond Public Works Department
450 Civic Center Plaza, Richmond, CA 94804
(510) 621-1612 | [email protected]
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Plan Update and Review
This LEP Plan will be reviewed annually by the Title VI Coordinator and updated as needed based on:
• Changes in community demographics (updated ACS 5-year estimates as released)
• Program experience — documented language access requests, complaint patterns, and staff feedback
• Changes to USDOT or Caltrans LEP policy guidance
• New federally funded programs or projects that generate new types of public contact
The plan will be fully updated as part of the Title VI Program Plan update at least every three years, or sooner if a material change in Richmond's LEP population is identified.
Updated demographic data will be incorporated at each review cycle and Table 1 will be revised accordingly.
The annual Goals and Accomplishments Report submitted to FHWA will include a section documenting LEP activity: language access requests received, languages needed, services provided, and any identified gaps.