San Rafael City Council
June 15, 2026

____________________________________________________________________________________

FOR CITY CLERK ONLY
Council Meeting:

Disposition:

Agenda Item No: SM 1.f
Meeting Date: June 15, 2026

SAN RAFAEL CITY COUNCIL AGENDA REPORT
Department: City Manager’s Office
Prepared by: Walter Gonzalez, Management Analyst
Angela Robinson Piñon, Assistant City
Manager
City Manager Approval: __________
TOPIC: TITLE VI (NON-DISCRIMINATION) PLAN
SUBJECT: RESOLUTION APPROVING A TITLE VI PLAN
RECOMMENDATION:

Staff recommends that the City Council adopt a resolution approving the Title VI Plan for the City of San Rafael and authorizing the City Manager to take all necessary actions to implement the resolution and take all actions to ensure ongoing compliance with Title VI of the Civil Rights Act of 1964 and related regulations.

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 financial assistance. As a recipient of federal funding for transportation, infrastructure, and other programs, the City of San Rafael is required to comply with Title VI and implementing regulations, including those of the U.S. Department of Transportation (49 Code of Federal Regulations (CFR) Part 21). Other nondiscrimination statutes that afford legal protection under the Federal Highway Administration (FHWA) Title VI (Non-discrimination) Plan include sex, age, disability, religion, sexual orientation, and other categories.

To maintain eligibility for federal and state funding from Caltrans, the City must adopt and periodically update a Title VI Plan. Caltrans is the compliance agent for federally funded projects through the FHWA and conducts program assessments of recipients to ensure compliance with Title VI requirements pursuant to 23 CFR 200.9(b)(7). The program outlines the policies, procedures, and commitments to ensuring nondiscrimination and equitable access to Public Works programs and services.

ANALYSIS:

Adoption of a Title VI Plan ensures compliance with federal civil rights requirements and preserves eligibility for critical federal and state funding. As a funding recipient, the City must demonstrate that its programs and services are delivered in a nondiscriminatory manner consistent with Title VI.

The proposed Title VI Plan (Attachment 2) establishes clear policies, roles, and procedures, including designation of a Title VI Coordinator, a standardized complaint process, and enhanced language access and outreach efforts. These elements improve consistency, transparency, and accountability.

SAN RAFAEL CITY COUNCIL AGENDA REPORT / Page: 2
The Title VI Plan can be implemented within existing resources and aligns with current staff functions within the Public Works Department and the City Manager’s Office. Failure to adopt a compliant Title VI Program could jeopardize Caltrans funding and expose the City to compliance risks. Adoption is therefore both a regulatory requirement and a strategic action that advances the City’s commitment to equitable service delivery.

This action directly supports the City’s FY 2025-2028 Strategic Plan, particularly goals related to advancing equity, strengthening community engagement, and delivering high-quality, accessible services. By improving outreach and access for historically underserved communities, including those with limited English proficiency, the Program helps ensure that all residents can meaningfully participate in and benefit from City services.

FISCAL IMPACT:

There is no direct fiscal impact associated with the adoption of the Title VI Plan. Staff time required to implement and maintain the program will be accommodated within the Public Works and City Manager’s Office budgets. Maintaining compliance with Title VI is essential to preserving eligibility for federal and state funding.

OPTIONS:

The City Council has the following options to consider in this matter:

1. Adopt the resolution.

2. Request modifications and continue the item.

3. Do not adopt the resolution and provide direction to staff.

RECOMMENDED ACTION:

Staff recommends that the City Council adopt a resolution approving the Title VI Plan for the City of San Rafael and authorizing the City Manager to take all necessary actions to implement the resolution and take all actions to ensure ongoing compliance with Title VI and related regulations.

ATTACHMENTS:

1. Resolution

2. Exhibit A – Title VI Plan
RESOLUTION NO.

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN RAFAEL APPROVING A

TITLE VI PLAN
WHEREAS, Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq.) provides that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under any program or activity receiving federal financial assistance; and WHEREAS, multiple similar statutes were created at later dates extending discrimination protections for sex, age, disability, religion, sexual orientation, gender identity, and other categories; and
WHEREAS, the City of San Rafael currently receives federal financial assistance from the California Department of Transportation (Caltrans) and is required to comply with Title VI and related non-discrimination laws and regulations; and WHEREAS, the City is committed to ensuring that no person is excluded from participation in, denied the benefits of, or otherwise discriminated against in any City program, service, or activity on the basis of race, color, or national origin; and WHEREAS, federal regulations issued by the U.S. Department of Transportation, including 49 Code of Federal Regulations Part 21, require recipients of federal funding to adopt and implement a Title VI program; and
WHEREAS, the City of San Rafael seeks to formalize its commitment to nondiscrimination and ensure compliance with all applicable federal and state civil rights laws.

NOW, THEREFORE, BE IT RESOLVED that the City Council:

1. Adopts the City of San Rafael Title VI Plan attached as Exhibit A; and

2. Authorizes the City Manager to implement this resolution and take all actions necessary to ensure ongoing compliance with Title VI and related regulations.

I, LINDSAY LARA, Clerk of the City of San Rafael, hereby certify that the foregoing resolution was duly and regularly introduced and adopted at a regular meeting of the City Council of the City of San Rafael, held on Monday, the 15th day of June 2026, by the following vote, to wit:

AYES: Councilmembers:

NOES: Councilmembers:

ABSENT: Councilmembers:

______________________
Lindsay Lara, City Clerk
City of San Rafael Title VI Plan

TITLE VI PLAN

TABLE OF CONTENTS
Non-Discrimination Policy Statement ........................................................................ 1 I. Introduction ............................................................................................................... 2 Title VI and Related Authorities.................................................................................. 2 Limited English Proficiency (LEP).............................................................................. 3 City Governance ....................................................................................................... 3 Organization Structure .............................................................................................. 3 Training..................................................................................................................... 4 Contracts and Agreements ....................................................................................... 5 Meaningful Access to Programs and Activities for Persons with Disabilities.............. 5 Data Collection ......................................................................................................... 5 Annual Work Plan ..................................................................................................... 6 Compliance and Enforcement................................................................................... 7 Review of City Directives .......................................................................................... 7 II. Title VI Notification and Complaint Procedures........................................................... 7 City of San Rafael Title VI Complaint Procedures ...................................................... 7 III. Public Participation Plan (PPP)................................................................................. 9 IV. Glossary ................................................................................................................. 10 APPENDIX A........................................................................................................... 13 APPENDIX B .......................................................................................................... 16 APPENDIX C .......................................................................................................... 19 APPENDIX D .......................................................................................................... 21 APPENDIX E........................................................................................................... 23 APPENDIX F........................................................................................................... 31 1 CITY OF SAN RAFAEL TITLE VI PLAN
Non-Discrimination Policy Statement
It is the policy of the City of San Rafael Department of Public Works that no person shall on the grounds of race, color, national origin, sex, disability, age, or other protected status be excluded from participation in, be denied the benefits of, or be subjected to discrimination in any operation of the City of San Rafael as provided by Title VI of the Civil Rights Act of 1964 and related statutes.

This policy applies to all operations of the Department of Public Works, including its contractors and anyone who acts on behalf of the Department. This policy also applies to the operations of any department or agency to which the City of San Rafael extends federal financial assistance. Federal financial assistance includes grants, training, use of equipment, donations of surplus property, and other assistance.

Prohibited discrimination may be intentional or unintentional. Seemingly neutral acts that have disparate impacts on individuals of a protected group and lack a substantial legitimate justification are a form of prohibited discrimination. Harassment and retaliation are also prohibited forms of discrimination.

Examples of prohibited types of discrimination based on race, color, national origin, sex, disability, age, or other protected status include: Denial to an individual any service, financial aid, or other benefit; Distinctions in the quality, quantity, or manner in which a benefit is provided; Segregation or separate treatment; Restriction in the enjoyment of any advantages, privileges, or other benefits provided; Discrimination in any activities related to highway and infrastructure or facility built or repaired; and Discrimination in employment.

Title VI compliance is a condition of receipt of federal funds. The Title VI Coordinators and other City staff, as described in this Plan, are authorized to ensure compliance with this policy, Title VI of the Civil Rights Act of 1964, 42 U.S.C § 2000d, and related statutes, and the requirements of 23 Code of Federal Regulation (CFR) pt. 200 and 49 CFR pt. 21.
___________________________ __________________
Paul Navazio Date
Interim City Manager
2 I. Introduction
Title VI of the Civil Rights Act of 1964 (Title VI) is a federal law that requires no person in the United States on the grounds of race, color, or national origin to be excluded from, or be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance. The Federal-Aid Highway Act of 1973 added the requirement that there be no discrimination on the basis of sex. Title VI applies to recipients and sub-recipients of federal financial assistance.

The City of San Rafael (City) may receive federal funding from the Federal Highway Administration (FHWA) and other federal program funding. Recipients of federal aid are required to comply with Title VI and the related Department of Transportation regulations (Title 49 CFR Part 21).

The primary goals and objectives of the City of San Rafael’s Title VI Plan are:
• To assign roles, responsibilities, and procedures for ensuring compliance with Title VI and related regulations and directives;
• To ensure that people affected by the City's programs and projects receive the services, benefits, and opportunities to which they are entitled without regard to race, color, national origin, age, sex, or disability;
• To prevent discrimination in the City's programs and activities; • To establish procedures for identifying impacts in any program, service, or activity that may create discriminatory adverse effects on any person because of race, color, national origin, age, sex, or disability; or on minority populations, low-income populations, the elderly, and all interested persons and affected Title VI populations;
• To establish procedures to review Title VI compliance within specific program areas within the City; • To set forth procedures for filing and processing complaints by persons who believe they have been subjected to discrimination under Title VI in the City's services, programs, or activities.

Title VI and Related Authorities
Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq.) states the following: “No person in the United States, on the grounds of race, color, or national origin, shall be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance.”
Section 504 of the Rehabilitation Act of 1973 (29 U.S.C. § 791 et seq.) prohibits discrimination on the basis of disability in programs and activities that receive federal financial assistance and in federally conducted programs.

The Age Discrimination Act of 1975 (42 U.S.C. §§ 6101-6107) prohibits discrimination on the basis of age in programs and activities receiving federal financial assistance.

Title IX of the Education Amendments Act of 1972 (20 U.S.C. §§ 1681-1688) provides that no person in the United States, on the basis of sex, shall be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving federal financial assistance.

The Civil Rights Restoration Act of 1987, P.L. 100-209, provides clarification of the original intent of Congress in Title VI of the 1964 Civil Rights Act, Title IX of the Educational Amendments Act of 1972, 3 the Age Discrimination Act of 1975, and Section 504 of the Rehabilitation Act of 1973.

Limited English Proficiency (LEP)
Limited English Proficiency persons refer to persons for whom English is not their primary language and who have a limited ability to read, write, speak, or understand English. It includes people who reported to the U.S. Census that they speak English less than very well, not well, or not at all.

LEP persons are entitled to language assistance under Title VI of the Civil Rights Act of 1964, and federal assistance recipients shall take reasonable steps to ensure meaningful access to benefits, services, information, and other important portions of their programs and activities.

Within this document, the terms non-English speakers, or Linguistically Diverse (LD) individuals, will be used instead of LEP.

The City has drafted a Language Access Plan (LAP), attached as Appendix E, including relevant data, to identify reasonable steps to provide language assistance for LD persons who seek meaningful access to the City's services.

City Governance
The residents of San Rafael sit at the top of the City’s organizational structure. They directly elect the Mayor, the four district-based City Councilmembers, the City Attorney, and the City Clerk. The Mayor and City Council also represent San Rafael on various regional boards and committees—such as the SMART Board, the San Rafael Sanitation District, the Marin Wildfire Authority, and others.

San Rafael is a full-service city, employing more than 400 full-time and part-time staff across 11 departments, each with its own specialized divisions and service areas.

The four district-elected Councilmembers and the at-large elected Mayor appoint members to the City’s Boards and Commissions, which serve as advisory bodies to the Council.

The Mayor and City Council hire and confirm the City Manager, who serves as the Chief Executive Officer of the municipal government. The City Manager oversees the administration of City services and programs, ensures enforcement of the Municipal Code and ordinances, and prepares the annual budget.

The City Manager also appoints Assistant City Managers and department directors.

Organization Structure
The City Manager is ultimately responsible for assuring full compliance with the provisions of Title VI of the Civil Rights Act of 1964 and related statutes and has directed that nondiscrimination is required of all City employees, contractors, and agents pursuant to 23 CFR Part 200 and 49 CFR Part 21.

The Title VI Coordinators are responsible for implementing the City’s Title VI Plan and coordinating the City’s compliance with Title VI and related statutes, regulations, and directives.

The City of San Rafael has designated an Assistant City Manager and Public Works Director to perform the duties of Title VI Coordinators.
4 Title VI Organization Chart
The Title VI Coordinators are responsible for:
• Submitting the Title VI Plan and annual reports on the City of San Rafael’s behalf. • Implementing the City’s discrimination complaint and compliance review procedure, receive and process Title VI discrimination complaints, and oversee the process to ensure that complaints are handled effectively.
• Receiving and responding to inquiries from City residents, participants, stakeholders, leadership, staff, and others regarding discrimination, and other inquiries regarding Title VI. • Coordinating Title VI program development, including the development of procedures for the collection and analysis of statistical data and a program to conduct Title VI reviews of program areas; and conduct annual Title VI assessments of pertinent program areas in each of their departments.
• Organizing and maintaining records of all complaints filed and compliance reviews conducted to ensure tracking of all discrimination complaints filed under federal non-discrimination Title VI requirements.
• Coordinating the creation and delivery of Title VI training. • Developing Title VI information for dissemination.
• Conducting Title VI reviews of program areas.
• Identifying deficiencies in compliance with Title VI requirements and make recommendations for remedial actions to be taken to resolve such deficiencies. • Establishing procedures to ensure that Title VI Assurances are incorporated into all federal-aid Contracts and Agreements.

Training
Training will be made available to City of San Rafael Department of Public Works staff responsible for implementing the Title VI Requirements. These trainings will occur at least every two years. The training will cover the Title VI Non-discrimination Policy Statement, complaint process, public participation plan, language access plan, and where to seek assistance for Title VI questions and concerns. All staff City Manager
Head of Agency
Assistant City Manager
and Public Works Director
Title VI Coordinators
5 receiving training will be required to sign a form acknowledging the Non-Discrimination policy. The standard acknowledgment is attached as Appendix C. Training attendance records will be maintained by the Department as part of the Title VI program documentation.

Contracts and Agreements
The Department of Public Works affirms its compliance with Title VI of the Civil Rights Act of 1964 and related nondiscrimination statutes. The Department provides assurance to the Federal Highway Administration (FHWA) that all federally funded programs and activities are administered in compliance with applicable nondiscrimination requirements.

The Department of Public Works will ensure that contracts for federally funded FHWA programs and activities administered by the Department contain Title VI Assurances. The Department further ensures that the required Title VI Assurances, including Appendices A and E of DOT Order 1050.2A, are incorporated into all consultant contracts and agreements involving federal funding. These assurances are included in Appendix F.

Meaningful Access to Programs and Activities for Persons with Disabilities It is the City's policy to administer its programs and activities in a manner that provides meaningful access to persons with disabilities in accordance with the Americans with Disabilities Act of 1990, as amended, and other related civil rights laws. The City will:
• Provide, at no cost, appropriate auxiliary aids and services, including but not limited to, qualified interpreters to individuals who are deaf or hard of hearing, and to other individuals as necessary to ensure effective communication and an equal opportunity to participate fully in the benefits, activities, programs and services provided by the City promptly and in such a way as to protect the privacy and independence of the individual.
• Ensure that the City's facilities and other facilities utilized by the City are physically accessible for individuals with disabilities.

Data Collection
The City of San Rafael Department of Public Works will be continually working to improve data collection and analysis methods to provide greater effectiveness of the Title VI Plan. The Department of Public Works may collect and analyze data related to their respective programs, projects, activities, and services. This data helps the Department of Public Works to determine the needs and characteristics of the communities impacted by its programs, projects, and services. In turn, this supports the Department in tailoring its services to its population, delivering effective and equitable services, and ensuring meaningful access to information, programs, and activities.

Demographic and related data collected and used by staff come from governmental sources responsible for collecting and analyzing the information to ensure consistency and accuracy. These sources include, but are not limited to, the U.S. Bureau of Labor Statistics, the U.S. Census Bureau, the U.S. Bureau of Economic Analysis, the California Department of Finance, the California Department of Labor, the California Employment Development Department, the Association of Bay Area Governments, and the Metropolitan Transportation Commission.

For federally funded projects, staff may use various methods to collect project-specific demographic data during public outreach. These methods may include social media releases, surveys, public meetings, and public comments collected on project websites.

For operational and maintenance services that are primarily request-driven or safety-driven, such as pothole repair, vegetation trimming, park maintenance, and illegal dumping response, services are provided based on reported needs and operational priorities rather than demographic analysis. Language accessibility measures, including Spanish-speaking staff, help ensure that residents have equitable access to these services.
6 Program Area Type of Data Collected &
Process for Collection
Intended Outcome of Data
Analysis
(i.e. Title VI Purpose for
Collecting Data)
Maintenance and Service
Requests
Services such as pothole repair,
flooding response, and illegal
dumping are request-driven or
safety driven. Requests are
received through phone calls,
service requests, or reporting
tools such as the SeeClickFix
app. Spanish speaking staff
assist residents when needed.

Ensure equitable access to
public services regardless of
race, color, national origin, or
language ability.

Transportation Planning &
Grant Programs
U.S. Census and American
Community Survey (ACS)
demographic data are used to
evaluate communities
potentially affected by
transportation projects. Some
grant programs require
demographic analysis of
disadvantaged communities.

Ensure transportation
investments consider impacts
to minority, low-income, and
disadvantaged communities
and comply with Title VI
requirements.

Permitting and Inspections Permitting staff interact directly with applicants and residents
during permit processing and
field inspections. Spanish
speaking staff assist residents
when language barriers exist,
and many small permit
inspections are conducted in
Spanish when necessary.

Ensure that linguistically
diverse residents are able to
understand permit
requirements and access
permitting services.

Public Outreach Activities Demographic information from U.S. Census and ACS may be
reviewed to understand
community characteristics
when conducting outreach or
project planning.

Help ensure outreach efforts
reach diverse populations and
underserved communities.

Annual Work Plan
Title VI Coordinators will annually establish and monitor program goals and maintain a Work Plan. Title VI Coordinators will ensure that training is conducted, that language translation services remain available, that public participation is optimal, and that appropriate Title VI signage is posted. This also includes updating community statistics and corresponding with the federal agency as necessary. The Annual Work Plan will guide updates to the Title VI Plan, which shall be updated every three years. The Annual Work Plan will be posted to the City’s website.
7 Compliance and Enforcement
The Department of Public Works shall make every effort to monitor, review, and report on compliance with Title VI. If the Department determines that after a desk audit review, compliance review, or complaint investigation, that a sub-recipient (e.g., contractors, vendors, consultants) or City employee is not in compliance with Title VI requirements, they will be notified in writing of the violation(s) or deficiencies and recommended corrective actions to resolve the violation(s) or deficiencies. Sub-recipients and employees found to be in noncompliance are expected to implement corrective actions within a reasonable period.

The Title VI Coordinator will provide assistance to ensure implementation of the corrective actions and that the violation(s) or deficiencies are sufficiently corrected.

Review of City Directives
The City Attorney’s Office will review City policy and procedural directives for any possible Title VI implications that may impact individuals or communities protected under Title VI of the Civil Rights Act of 1964. If a directive is believed to have Title VI implications, it will be discussed with the Title VI Coordinator and Department Directors as appropriate.

II. Title VI Notification and Complaint Procedures
The Department of Public Works will ensure that people may participate in, enjoy the benefits of, and be free from discrimination under any program or activity it administers without regard to any protected status.

The Department will display the "Notice of Non-Discrimination" (Appendix A and A-1) in a prominent place for public view and on the City’s website.

City of San Rafael Title VI Complaint Procedures
Submission of Complaint
If a person believes they have received discriminatory treatment by a City of San Rafael employee based on race, color, or national origin (including Limited English Proficiency), or any other status protected by Title VI, the person will have the right to file a Title VI complaint with the City. The complaint must be filed within 180 days of the alleged discriminatory incident.

Preparation of Complaint by Complainant
The City’s Title VI Coordinator will only process complaints that are complete and include the following information:
• Complainant’s contact information
• Date(s) of alleged discriminatory act(s)
• Details of alleged discrimination
• Identification of the City Department responsible for the alleged discrimination. • Basis of the complaint (e.g., race, color, or national origin) • Signature of the complainant or complainant’s representative The Title VI Complaint form is available on the City’s website in English and Spanish at www.cityofsanrafael.org. Copies may also be obtained from the City Manager’s Office (1400 Fifth Avenue, Room 203) and at the Department of Public Works (111 Morphew). A sample of the Title VI Complaint form is provided as Appendix B. In cases where a complainant is unable or incapable of providing a written complaint, a verbal complaint may be made. If submitted via email, the email should include the signed and dated complaint as an attachment. Any person requiring a reasonable accommodation may contact the Title VI Coordinator to obtain assistance in filing a Complaint. 8 No person who files a complaint, nor any person who cooperates in the investigation of the complaint, shall be subjected to retaliation, and the City shall take reasonable steps to protect such persons from retaliatory actions.

Every effort will be made to resolve complaints as soon as possible. Before filing a complaint and at any time during an investigation, the complainant may contact the Title VI Coordinator at (415) 485-3070 or via email at [email protected] to attempt to resolve the matter informally.

Once received, the Title VI Coordinator will assign a number to each complaint, and each will be included in the City’s Title VI Complaint Log (Appendix D). The Complaint Log is maintained in accordance with federal nondiscrimination requirements and is made available to Caltrans or the FHWA upon request.

Records related to Title VI complaints, investigations, training, outreach activities, and program reviews are maintained by the Title VI Coordinator in accordance with applicable federal and state record retention requirements and are available for review by Caltrans or FHWA upon request.

If no Title VI complaints are received during a reporting period, the log will indicate that no complaints were filed.

Investigation of Complaints
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 a sub-recipient (e.g., the City of San Rafael) via email are to be forwarded to Caltrans within one business day of receipt to [email protected] be submitted to the FHWA California Division Office. If FHWA’s Headquarters Office of Civil Rights (HCR) determines that Caltrans can investigate a Title VI complaint against a sub-recipient, HCR may delegate the task of investigating the complaint to Caltrans.

Title VI Complaints Processed Under the Federal Transit Administration (FTA): Title VI complaints filed with Caltrans against a sub-recipient will be investigated by Caltrans. If the complaint is filed with the sub-recipient, the sub-recipient is responsible for investigating the complaint in accordance with FTA Circular 4702.1B. FTA recommends, but does not require, that individuals first file a complaint directly with their transit provider to allow the provider to resolve the situation. FTA grantees are required to have local complaint procedures.

A person may also file a complaint directly with:

Federal Highway Administration
U.S. Department of Transportation
Office of Civil Rights
1200 New Jersey Avenue, SE
8th Floor E81-105
Washington, DC 20590
https://highways.dot.gov/civil-rights/title-vi-civil-rights-act-1964-and-additional- nondiscriminationrequirements Federal Transit Administration Civil Rights Division
Attention: Complaint Team
East Building, 5th Floor – TCR 1
200 New Jersey Avenue, SE
Washington, DC 20590
California Department of Transportation
Office of Civil Rights
9 Attention: Title VI Branch Manager
P.O. Box 942874, MS 79
Sacramento, CA 94274-0001
Email: [email protected]
https://dot.ca.gov/programs/civil-rights/title-vi
III. Public Participation Plan (PPP)
The Department of Public Works is committed to advancing projects, programs, and services delivered by the City that are sensitive to the various demographic backgrounds within the Department. The Department’s encouragement of Public Participation promotes public involvement in the planning and decision-making process of projects, programs, and services.

As a recipient of federal funding, the Department is required to adhere to Title VI of the Civil Rights Act of 1964 and to integrate the Public Participation into its Title VI Plan. This Plan provides guidelines for involving the public to ensure that all groups are represented and their needs considered. The Department is committed to ensuring it serves the residents and businesses of the City fairly, consistently, and in the most cost-efficient and appropriate manner within available resources.

Goals and Objectives
The goal of the Public Participation Plan (PPP) is to offer a variety of opportunities for the public to engage in planning and decision-making activities. To meet this goal, the objectives of the PPP are as follows:
• To determine what non-English languages and/or other barriers may exist to public participation within the City service area.
• To provide a general notification of meetings for public input, in a manner that is understandable to all populations in the service area.
• To hold meetings in locations that are accessible and reasonably welcoming to all area residents, including, but not limited to, minority, LD, and low-income members of the public. • To utilize a variety of communication methods to capture public input from populations that are not likely to attend or engage in public meetings.

Public Comment Process Offered by the City Council and Boards, Commissions, and Committees The following section briefly summarizes the public comment process for the City's legislative and advisory bodies.

Meetings Overview: The public has the right to express their opinion during regular City Council meetings held at least two Mondays a month at 6:00 p.m., as well as at meetings of the City's boards, commissions, and committees. Information about City Council as well as the City's boards, commissions, and committees is available on the City website at https://www.cityofsanrafael.org/guide-publicmeetings/.

Providing Public Comment: Public comments can be provided in person or via a written public comment. Speakers will have two minutes to provide their comments during the meeting. Written comments may be submitted by email by 4:00 p.m. on the day of the meeting. All relevant comments received verbally or in writing at a public meeting, or as otherwise submitted to the City before the established deadline, will be entered into the public record of the comment process.

Interpretation Services: The City will provide interpretation services when requested 48 hours in advance of a public meeting. Information on how to request interpretation may be found here:
10 https://www.cityofsanrafael.org/request-for-interpretation/.

Meeting Notices: Public meeting agendas and notices are posted on the City’s website and on the City’s official notice board at San Rafael City Hall (1400 Fifth Avenue, San Rafael, CA 94901).

Outreach and Engagement Guide
The City is committed to ensuring that projects, programs, and services delivered by the City are sensitive to the various demographic backgrounds within the City. The City's Outreach and Engagement Guide is a tool for City staff to promote public involvement in the planning and decision-making process of projects, programs, and services. The Outreach and Engagement Guide help City staff to:
• Assess what barriers may exist to ensuring equitable access to decision-making, including, but not limited to, income level, language accessibility, and disability • Plan meetings at times and in locations that are accessible and reasonably welcoming to all residents and stakeholders
• Utilize a variety of communication methods to capture public input from populations that are not likely to attend or engage in public meetings
The Department of Public Works will engage the community through the City’s website, social media, and brochures placed at the library, community centers, public parks, and recreation areas within the communities. Department staff and/or a contracted non-English language interpreter are available upon request to attend community meetings to inform residents of the Department’s services and provide them an opportunity to express their input in a language they are comfortable communicating in.

The following are examples of techniques the Department may use to inform, educate, and gain input from the public about the Department’s projects, services, or activities:
• Surveys or questionnaires - mail-in, online, telephone, personal interview • Articles or press releases in the appropriate publications • Distribution of informal reports, flyers, or brochures • Informal presentations at community forums
• Information about meetings, public hearings, and special events on the City’s website • Direct mailings to those expressing interest in or commenting about certain topics IV. Glossary
Affected parties: Persons protected against discrimination because of race, color, national origin, sex, age, disability, or income level by Title VI and related legal requirements.

Contractor: A person or entity who has entered into an agreement with the City that is subject to Title VI Requirements.

Proposed Project: A project that receives federal funds and is subject to Title VI Requirements.

Subrecipient: A person or entity that receives federal funds from the City to be used by the entity to further the objectives of the federal grant. The City is the recipient of the grant, and the person or entity is a sub-recipient of those grant funds.

Title VI Assurances: Conditions imposed upon contractors or sub-recipients as a result of federal funding being directly or indirectly provided to the contractor or sub-recipient. 11 Title VI Requirements: The nondiscrimination provisions contained in Title VI of the Civil Rights Act of 1964, the Civil Rights Restoration Act of 1987, the Federal Aid Highway Act of 1973, the Age Discrimination Act of 1975, the Americans with Disabilities Act of 1990, and Section 504 of the Rehabilitation Act of 1973.

Adverse Effects: The totality of significant individual or cumulative human health or environmental effects, including interrelated social and economic effects.

Federal Assistance: Includes grants and loans of federal funds; the grant or donation of federal property and interests in property; the detail of federal personnel, federal property, or any interest in such property without consideration or at a nominal consideration or at a consideration which is reduced for the purpose of assisting the recipient, or in recognition of the public interest to be served by such sale or lease to the recipient; and any federal agreement, arrangement or other contracts which has, as one of its purposes, the provision of assistance.

Limited English Proficiency (LEP): Describes individuals who do not speak English as their primary language and have a limited ability to read, write, speak, or understand English. These individuals may face challenges accessing services, information, and opportunities readily available to English-speaking populations.

Linguistically Diverse (LD): Describes individuals who speak different languages or different forms of the same language from the dominant culture in a particular setting.

Low-Income: A person whose median household income is at or below the Department of Health and Human Services Poverty guidelines (see http://aspe.hhs.gov/poverty/).

Low-Income Population: Any readily identifiable group of low-income persons who live in geographic proximity and, if circumstances warrant, geographically dispersed/transient persons (such as migrant workers or Native Americans) who will be similarly affected by a proposed local City program, policy, or activity.

Minority – A person who is:

Black – A person having origins in any of the black racial groups of Africa; Hispanic – A person of Mexican, Puerto Rican, Cuban, Central or South American, or other Spanish culture or origin, regardless of race;
Asian American – A person having origins in any of the original peoples of the Far East, Southeast Asia, the Indian sub-continent, or the Pacific Islands; or American Indian and Alaskan Native – A person having origins in any of the original peoples of North America and who maintains cultural identification through tribal affiliation or community recognition.

Minority Population: Any readily identifiable group of minority persons who live in geographic proximity and, if circumstances warrant, geographically dispersed/transient persons (such as migrant workers or Native Americans) who will be similarly affected by a proposed local City program, policy, or activity.

Non-Compliance: A recipient has failed to meet prescribed requirements and has shown an apparent lack of good faith effort in implementing all the requirements of Title VI and related statutes.

Recipient: Any state, territory, possession, the District of Columbia, Puerto Rico, or any political subdivision, or instrumentality thereof, or any public or private agency, institution, organization, or other entity, or any individual in any state, territory, possession, the District of Columbia, or Puerto Rico, to 12 whom federal assistance is extended, either directly or through another recipient, for any program.

Recipient includes any successor, assignee, or transferee thereof, but does not include any ultimate beneficiary under any such program.

Disproportionate Adverse Effects on Minority and Low-Income Populations: An adverse effect that is predominantly borne by a minority population and/or a low-income population, or will be suffered by the minority population and/or low-income population, and is shown to be appreciably more severe or greater in magnitude than the adverse effect that will be suffered by the non-minority population and/or non-low-income population.
13 APPENDIX A

NOTICE OF NON-DISCRIMINATION
14 APPENDIX A

NOTICE OF NON-DISCRIMINATION
The City of San Rafael (City) does not discriminate on the basis of race, color, national origin, disability, age, sex, or any other protected status in the administration of its services, programs or activities, and, the City does not intimidate or retaliate against any individual or group because they have exercised their rights to participate in actions protected, or oppose action prohibited, by Title VI of the Civil Rights Act of 1964, 42 U.S.C § 2000d, and related statutes, and the requirements of 23 Code of Federal Regulation (CFR) pt. 200 and 49 CFR pt. 21, or for the purpose of interfering with such rights.

The City’s Title VI Coordinator is responsible for the coordination of compliance efforts and receipt of inquiries concerning non-discrimination requirements implemented by Title VI of the Civil Rights Act of 1964, 42 U.S.C § 2000d, and related statutes; the requirements of 23 Code of Federal Regulation (CFR) pt. 200 and 49 CFR pt. 21; Section 504 of the Rehabilitation Act of 1973; the Age Discrimination Act of 1975; Title IX of the Education Amendments of 1972; and Section 13 of the Federal Water Pollution Control Act Amendments of 1972 (hereinafter referred to collectively as the federal non-discrimination laws).

Any person who believes that they have been discriminated against may file a written complaint with the City of San Rafael within 180 days of the alleged discrimination. Additional information and Title VI Complaint Forms can be obtained on the City of San Rafael website, at www.cityofsanrafael.org. Title VI Complaint Forms can also be obtained at the San Rafael City Hall from the City Manager’s Office. To file a Title VI discrimination complaint, please use the following contact information:

City of San Rafael
Attn: Title VI Coordinator
City Manager's Office
1400 5th Ave.

San Rafael, CA 94901
Email: [email protected]
15 AVISO DE NO DISCRIMINACIÓN
La ciudad de San Rafael (la «Ciudad») no discrimina por motivos de raza, color, origen nacional, discapacidad, edad, sexo o cualquier otra condición protegida en la administración de sus servicios, programas o actividades; asimismo, la Ciudad no intimida ni ejerce retaliaciones contra ninguna persona o grupo por haber ejercido su derecho a participar en acciones protegidas, o a oponerse a acciones prohibidas, por el Título VI de la Ley de Derechos Civiles de 1964, 42 U.S.C. § 2000d y los estatutos relacionados, así como los requisitos del Código de Regulaciones Federales (CFR) 23, parte 200, y 49 CFR, parte 21, o con el propósito de interferir con dichos derechos.

El Coordinador del Título VI de la Ciudad es responsable de la coordinación de los esfuerzos de cumplimiento y de la recepción de consultas relativas a los requisitos de no discriminación implementados por el Título VI de la Ley de Derechos Civiles de 1964, 42 U.S.C § 2000d, y los estatutos relacionados; los requisitos del Código de Regulaciones Federales (CFR) 23, parte 200, y 49 CFR, parte 21; la Sección 504 de la Ley de Rehabilitación de 1973; la Ley contra la Discriminación por Edad de 1975; el Título IX de las Enmiendas a la Educación de 1972; y la Sección 13 de las Enmiendas a la Ley Federal de Control de la Contaminación del Agua de 1972 (en lo sucesivo denominadas colectivamente las leyes federales contra la discriminación).

Cualquier persona que considere que ha sido discriminada puede presentar una queja por escrito ante la ciudad de San Rafael en un plazo de 180 días a partir de la supuesta discriminación. Se puede obtener información adicional y los formularios de queja del Título VI en el sitio web de la ciudad de San Rafael, en www.cityofsanrafael.org. Los formularios de queja del Título VI también se pueden obtener en el Ayuntamiento de San Rafael, en la Oficina del Administrador Municipal. Para presentar una queja por discriminación en virtud del Título VI, utilice la siguiente información de contacto:

Ciudad de San Rafael
A la atención de: Coordinador del Título VI
Oficina del Administrador Municipal
1400 5th Ave.

San Rafael, CA 94901
Correo electrónico: [email protected]
16 APPENDIX B

DISCRIMINATION COMPLAINT FORM
17 City of San Rafael
Title VI and related statutes
Discrimination Complaint Form

FOR OFFICE USE ONLY
Date: Reviewer Initials:

Name of Complainant: Home Telephone Number: Work Telephone Number:

Mailing Address:

What is the most convenient time for us to contact you about this complaint? Basis of Discriminatory Action(s):

RACE COLOR NATIONAL ORIGIN

INTIMIDATION/RETALIATION

SEX AGE DISABILITY
Date and place of alleged discriminatory actions. Please include earliest date of discrimination and most recent date of discrimination:

How were you discriminated against? Describe the nature of the action, decision, or conditions of the alleged discrimination. Explain as clearly as possible what happened and why you believe your protected status was a factor in the discrimination. Include how other persons were treated differently from you. (Attach additional page(s), if necessary).

Name(s) of City agency or program/activity responsible for the discriminatory action(s):

Names of persons (witnesses, or others) whom we may contact for additional information to support or clarify your complaint: (Attached additional page(s), if necessary).

Name Address Telephone
_
_
18 Ciudad de San Rafael
Formulario de queja por discriminación
del Título VI y leyes relacionadas

SOLO PARA USO EN LA OFICINA
Fecha: Iniciales del revisor:

Nombre del reclamante: Número de teléfono particular: Número de teléfono del trabajo:

Dirección postal:
¿Cuál es el mejor horario para que nos pongamos en contacto con usted en relación con esta reclamación? Motivo o motivos de la acción o acciones discriminatorias:
______RAZA ______COLOR DE PIEL______ ORIGEN NACIONAL
________INTIMIDACIÓN/REPRESALIAS

SEXO EDAD DISCAPACIDAD
Fecha y lugar de los supuestos actos discriminatorios. Indique la fecha más reciente y la fecha más antigua en las que se produjeron los actos discriminatorios:
¿De qué manera se le discriminó? Describa la naturaleza de la acción, la decisión o las circunstancias de la supuesta discriminación. Explique con la mayor claridad posible lo que ocurrió y por qué cree que su condición de persona protegida fue un factor determinante en la discriminación. Indique también en qué se diferenció el trato que recibieron otras personas del que usted recibió. (Adjunte páginas adicionales si es necesario).

Nombre(s) del departamento de la ciudad o programa/actividad responsable(s) de la(s) acción(es) discriminatoria(s):

Nombres de las personas (testigos u otras personas) con las que podríamos ponernos en contacto para obtener información adicional que respalde o aclare su reclamación: (Adjunte una o varias páginas adicionales, si es necesario).

Nombre Dirección Teléfono
_
_
19 APPENDIX C

STAFF TRAINING FORM
20 APPENDIX C

TITLE V STAFF TRAINING FORM
No person shall, on the grounds of race, color, national origin, sex, disability, age, or any other protected status, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any service, program, or activity receiving federal financial assistance.

Resident questions or complaints shall be directed to the City of San Rafael's Title VI Coordinator at (415) 485-3070 or via email at [email protected].

I hereby acknowledge receipt of the City of San Rafael’s Title VI Plan and Language Access Plan. I have read the plan and am committed to ensuring that no person is excluded from participation in or denied the benefits of services delivered by the City of San Rafael based on race, color, national origin, sex, disability, age, or any other protected status.

Signature
Print Name
Date
21 APPENDIX D

TITLE VI INVESTIGATIONS, COMPLAINTS, AND LAWSUITS

TRACKING FORM
22 APPENDIX D
LIST OF TITLE VI INVESTIGATIONS, COMPLAINTS, AND LAWSUITS* Action Date
(Month,
Day, Year)
Jurisdiction Completeness Summary
(Basis of complaint: Race, Color,
or National Origin)
Status Action(s)
Taken
Investigations
Lawsuits
Complaints
*As of the date of the issuance of this Title VI Plan, the City is not aware of any investigations, lawsuits, or complaints relating to Title VI.
23 APPENDIX E

LANGUAGE ACCESS PLAN
24 APPENDIX E

LANGUAGE ACCESS PLAN
I. Purpose and Vision
This City’s Language Access Plan (“Plan” or “LAP”) is designed to inform the public and stakeholders of the City’s efforts to comply with laws and regulations related to language access. The Plan looks to enhance the ability of non-English-speaking populations to participate in civic activities and access City services. It guides all City departments, staff, and affiliates on standards and service offerings related to translation, interpretation, and service delivery to linguistically diverse (LD) individuals.

II. Definitions

1. Certified Multilingual (Bilingual) Staff – An employee who has been approved for bilingual pay incentive as specified in their applicable labor agreement.

2. Interpretation – The act of listening to a communication in one language (source language) and orally converting it into another language (target language) while retaining the same meaning.

3. Language Assistance (Access) Services – Oral and written language services needed to assist LD individuals to communicate effectively with staff, and to provide LD individuals with meaningful access to, and an equal opportunity to participate fully in, the services, benefits, activities, and other programs.

4. Limited English Proficiency (LEP) – Describes individuals who do not speak English as their primary language and have a limited ability to read, write, speak, or understand English. These individuals may face challenges accessing services, information, and opportunities readily available to English-speaking populations.

5. Linguistically Diverse (LD) – Describes individuals who speak different languages or different forms of the same language from the dominant culture in a particular setting.

6. Meaningful Access – Language assistance that results in accurate, timely, and effective communication at no cost to the LD individual. For LD individuals, meaningful access refers to access that is not significantly restricted, delayed, or inferior as compared to programs or activities provided to English-proficient individuals.

7. Priority Language – A priority language is any language identified through demographic analysis as meeting or exceeding the 5% threshold established by the Dymally-Alatorre Bilingual Services Act.

8. Qualified Interpreter – An interpreter who has been professionally trained and/or demonstrated competence to interpret through certification, or comparable testing, and is authorized to do so by contract with the City. Qualified interpreters must also demonstrate knowledge of professional standards and adherence to the corresponding professional code of ethics, as well as familiarity with required City terminology.

9. Qualified Translator – A translator who has been professionally trained and/or demonstrated competence to translate through certification or comparable testing and is authorized to do so by contract with the City. Qualified translators must also demonstrate knowledge of professional standards and adherence to the corresponding professional code of ethics, as well as familiarity with required City terminology.

10. Translation – The replacement of a word, phrase, or text in one language (source language) with an equivalent-meaning word, phrase, or text in another language (target language).

11. Vital Documents – are documents that contain critical pieces of information an individual needs to access, retain, or understand rights and responsibilities within a program or service. Examples include applications, request or intake forms, registration materials, reporting tools, agreements, and complaint forms.
25 III. Authority and Guidance
Federal Authority
• Title VI of the Civil Rights Act of 1964: Prohibits discrimination based on race, color, or national origin in programs receiving federal financial assistance. This has been interpreted to mandate the provision of translation and interpretation services where necessary to ensure equal access to services.
• Policy Guidance Concerning Recipients’ Responsibility to Limited English Proficient (LD) Persons: Established best practices for Language Access Plans, and required local agencies that receive DOT funding to provide meaningful access to services to LD individuals.

State Authority
• Dymally-Alatorre Bilingual Services Act: California public agencies are required to make every effort to provide language access services when at least 5% of the population served consists of individuals who speak a language other than English or cannot communicate effectively because it is not their primary language.
• The Unruh Civil Rights Act (California Civil Rights Act): Prohibits discrimination by agencies that receive state funds and requires them to provide equal access to benefits without regard to the beneficiary’s race, color, national origin, or ethnic group identification, among other factors.

Alignment to San Rafael Policy
• San Rafael’s Strategic Plan 2025-2028: G.2.3 Develop and implement the City’s Language Resource Access Plan to improve multilingual engagement practices. • City of San Rafael’s 2040 General Plan: Program EDI-1.3A: Removing Language Barriers.

Ensure that Latino and other non-English-speaking populations may actively participate in local decision-making through such methods as bilingual notices, translation of meeting materials, the use of accessible (non-jargon) and culturally competent language, Spanish language meetings, new platforms for commenting (such as Facebook and Zoom), and having interpreters at public meetings.

IV. Four Factor Analysis
This section uses HUD’s four-factor analysis to determine the eligible LD population(s) and the level of language services to be provided to LD individuals by the City. The four-factor analysis is intended to provide flexibility in implementing a program that meets the intent of federal guidelines for an LAP without imposing undue burdens on recipients’ or subrecipients’ financial resources or organizational capacity.

The four factors include:

1. The number or proportion of LD individuals of a particular language group eligible to be served or likely to be encountered in the eligible service population;

2. The frequency with which LD individuals of different language groups come in contact with the service branch.

3. The nature and importance of the activities provided by the service branch; and

4. The resources available to the service branch to provide language assistance.

In accordance with US DOT guidelines, the City examined multiple data sources and conducted targeted outreach with staff and LD persons to develop the four-factor analysis.

Factor 1: The number or proportion of LD individuals of a particular language group eligible to be served or likely to be encountered in the eligible service population.

For the Factor 1 Analysis, the City analyzed the US Census Bureau American Community Survey (ACS) data to identify the City’s LD population. The ACS is a continuous nationwide survey conducted monthly by the US Census Bureau. It is intended to measure the changing socioeconomic characteristics and conditions of the population on a regular basis.
26 ACS reports data based on the four categories of English-speaking ability: “very well,” “well,” “not well,” and “not at all.” The City defines the LD population as individuals who speak English less than “very well,” which is consistent with US DOT guidelines.

As shown in Table 1 below, approximately 20.4% of residents in the City of San Rafael are considered Linguistically Diverse (LD) persons, those who speak English less than "very well." The largest share of LD persons speak Spanish (16.3% of the community), followed by Other and Unspecified languages (1.3%), Other Indo-European languages (0.6%), Vietnamese (0.4%), and Tagalog, including Filipino (0.4%). The table shows that Spanish is by far the dominant non-English language, representing 28.3% of the total population 5 years and over, and accounting for approximately 80% of all LD persons in San Rafael. No individual non-Spanish-language group accounts for more than 1.3% of the total community population with limited English proficiency.

Table 1: English Proficiency by Language Spoken at Home for San Rafael's Residents Language Group Population Estimate Percentage of
Population
Population 5 Years and Over 57,544 (X)
Speak Only English 35,646 61.9%
Spanish: 16,300 28.3%
Speak English "very well" 6,930 12.0%
Speak English less than "very well" 9,370 16.3%
French, Haitian, or Cajun: 490 0.9%
Speak English "very well" 414 0.7%
Speak English less than "very well" 76 0.1%
German or other West Germanic languages: 545 0.9%
Speak English "very well" 471 0.8%
Speak English less than "very well" 74 0.1%
Russian, Polish, or other Slavic languages: 505 0.9%
Speak English "very well" 306 0.5%
Speak English less than "very well" 199 0.3%
Other Indo-European languages: 1,264 2.2%
Speak English "very well" 914 1.6%
Speak English less than "very well" 350 0.6%
Korean: 328 0.6%
Speak English "very well" 133 0.2%
Speak English less than "very well" 195 0.3%
Chinese (incl. Mandarin, Cantonese): 475 0.8%
Speak English "very well" 332 0.6%
Speak English less than "very well" 143 0.2%
Vietnamese: 299 0.5%
Speak English "very well" 69 0.1%
Speak English less than "very well" 230 0.4%
Tagalog (incl. Filipino): 441 0.8%
Speak English "very well" 213 0.4%
Speak English less than "very well" 228 0.4%
Other Asian and Pacific Island languages: 316 0.5%
Speak English "very well" 165 0.3%
Speak English less than "very well" 151 0.3%
Arabic: 78 0.1%
Speak English "very well" 78 0.1%
Speak English less than "very well" 0 0%
Other and unspecified languages: 857 1.5%
Speak English "very well" 120 0.2%
Speak English less than "very well" 737 1.3%
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, 2024. Accessed March 13, 2026. 27 Under the Dymally-Alatorre Bilingual Services Act and the US DOT's Safe Harbor Provision, recipients must make every effort to provide language access services for any language group that constitutes 5% or more of the eligible service population. Spanish is the only language group in San Rafael that meets this threshold, making it the City's priority language for LD service delivery.

Factor 2: The frequency with which LD individuals of different language groups come in contact with the city and its services.

LD individuals access City services through various channels, including in person, online, over the phone, and by mail. To understand how frequently LD community members engage with City services, the City conducted a staff survey to gauge the frequency of contact. Additionally, the City conducted LD surveys and focus groups to determine the frequency of contact with City services.

According to the survey results, over 78% of City staff reported assisting at least one LD individual daily, and more than a quarter of respondents worked with three or more LD clients each day, clearly indicating that LD residents utilize city services. Moreover, 36% of staff noted encountering at least one LD client per day who could not be served due to language access barriers. Most of the LD individuals whom staff encounter speak Spanish. The City’s experience with LD populations has led it to focus on making efforts primarily to Spanish-speaking populations, by translating documents, for example. As shown in the table above, this experience is largely consistent with the U.S. Census Data that shows the share of the population by language spoken at home and English proficiency.

To assess how frequently Linguistically Diverse (LD) community members engage with City services, the City conducted a community survey reaching 82 residents and workers. Of respondents, 77% live in and 76% work in San Rafael. The most frequently accessed services included the Library, Recreation, and Public Works, departments that serve a broad cross-section of the community. Over half of respondents (54%) reported having needed language assistance when accessing City services, and 32% of those who interacted with staff in the past 12 months reported being offered language assistance. Consistent with Census data, 77% of survey respondents identified Spanish as their primary language, confirming that Spanish-speaking residents represent the most frequent LD contact point across City departments and supporting the City's ongoing prioritization of Spanish-language services.

Factor 3: The nature and importance of the program, activity, or service to LD individuals.

San Rafael is a full-service city that delivers a broad range of public services to all residents and visitors.

These include public safety, law enforcement, planning and building, library and community programs, early childhood education, environmental sustainability, parking enforcement, and maintenance of roads, traffic signals, parks, and playgrounds. The City also supports business development and economic vitality.

Several of these services carry high stakes for individuals with limited language access, particularly those involving public safety, law enforcement, and legal processes.

The City conducts public business through City Council meetings, Planning Commission meetings, and other official bodies. Without language access, LD residents are effectively excluded from the decisions that shape their community.

The City is keenly aware that approximately 20 percent of the City’s residents are LD and, therefore, it is highly likely that LD individuals will be a stakeholder in all City projects, programs, and services. If City staff are not able to complete a conversation, staff will reach out to a certified bilingual employee to ensure the customer is able to be served. As such, when Staff has encountered the need for interpretation services, Staff has provided the services readily. Moreover, as mentioned, the City often proactively translates outreach materials into Spanish.

Factor 4: Determine the resources available to assist LD individuals.

The City of San Rafael recognizes that meaningful language access is crucial to providing equitable 28 service delivery and fostering community engagement. However, like many local jurisdictions, the City operates within a complex and resource-constrained budget framework. As a result, the City must be strategic and deliberate in allocating resources to ensure that expenditures yield the most significant benefit for the community.

Despite these constraints, the City remains committed to enhancing language access for LD individuals.

To support this commitment, San Rafael has implemented a range of targeted initiatives aimed at improving language access services:

1. Bilingual Pay Incentive – Compensation is provided to qualified employees who pass a formal examination demonstrating proficiency in a language other than English, thereby encouraging and supporting a multilingual workforce.

2. Language Access Lines for Public Safety – The Police Department utilizes language access lines to provide real-time interpretation services during interactions with LEP/LD individuals.

3. Interpretation for Public Meetings – Budget allocations support the provision of interpretation services for City Council meetings upon request, ensuring that public participation is inclusive and accessible.

4. Technology-Enhanced Language Access – The City has invested in modern tools, including AI-powered translation and interpretation software, to expand access to digital services and communications. Software is coupled with bilingual staff review when possible

5. Multilingual Signage and Materials – Key public information is translated and displayed in multiple languages to ensure clarity and accessibility for all community members.

6. Departmental Language Access Funding – Departments are directed to allocate funds for language access needs as appropriate, based on service population and program requirements.

7. Website Translation – Visitors can select the language via an integrated Google Translate dropdown menu.

V. Actions to Implement the LAP
To support this commitment to providing equitable services to LD, San Rafael will implement a range of targeted initiatives aimed at improving language access services for our priority language(s):

1. Post Non-Discrimination Policy Statement online and in highly visible locations in City facilities

2. Post Title VI Rights Poster online and in highly visible locations in City facilities

3. Designate the Title VI Coordinator

4. Create a Title VI webpage on the City’s website

5. Maintain a log to track interpretation and translation services requested by the public or provided to the public

6. Develop and launch the Title VI Complaint Form

7. Establish a single point of contact for language access support

8. Continue to identify and translate vital documents

9. Continue to recruit and retain certified bilingual staff and develop an internal directory to identify language support when needed

10. Maintain a multilingual city website

11. Continue to provide interpretation for public meetings upon request

12. Continue to provide multilingual signage and materials

13. Develop a translation request form for City documents

14. Continue investments in technology-enhanced language access services

15. Develop best practices and provide guidance to staff, along with training to support implementation

16. Maintain language access phone lines for public safety

17. Deploy “I speak” badges and pins

18. Incorporate language access services requirements on relevant contracts and agreements as required
29 To ensure continuous compliance, the City will regularly review the Title VI Implementation Plan, Language Access Plan, and relevant work plans. As new regulations are created, the City will act promptly to update the existing plans and relevant resources. 30 31

APPENDIX F

US DOT TITLE VI ASSURANCES
32 US DOT Title VI Assurances A-E

APPENDIX A
During the performance of this contract, the contractor, for itself, its assignees, and successors in interest (hereinafter referred to as the “contractor”) agrees as follows:

1. Compliance with Regulations: The contractor (hereinafter includes consultants) will comply with the Acts and the Regulations relative to non-discrimination in federally-assisted programs of the U.S.

Department of Transportation, Federal Highway Administration, as they may be amended from time to time, which are herein incorporated by reference and made a part of this contract.

2. Non-discrimination: The contractor, with regard to the work performed by it during the contract, will not discriminate on the grounds of race, color, national origin, age, sex, or disability in the selection and retention of subcontractors, including procurements of materials and leases of equipment. The contractor will not participate directly or indirectly in the discrimination prohibited by the Acts and the Regulations, including employment practices when the contract covers any activity, project, or program set forth in Appendix B of 49 CFR Part 21.

3. Solicitation for Subcontracts, Including Procurements of Materials and Equipment: In all solicitations, either by competitive bidding, or negotiation made by the contractor for work to be performed under a subcontract, including procurements of materials, or leases of equipment, each potential subcontractor or supplier will be notified by the contractor of the contractor’s obligations under this contract and the Acts and the Regulations relative to Non-discrimination on the grounds of race, color, national origin, age, sex, or disability.

4. Information and Reports: The contractor will provide all information and reports required by the Acts, the Regulations, and directives issued pursuant thereto and will permit access to its books, records, accounts, other sources of information, and its facilities as may be determined by the Recipient or the FHWA to be pertinent to ascertain compliance with such Acts, Regulations, and instructions. Where any information required of a contractor is in the exclusive possession of another who fails or refuses to furnish the information, the contractor will so certify to the Recipient or the FHWA, as appropriate, and will set forth what efforts it has made to obtain the information.

5. Sanctions for Noncompliance: In the event of a contractor’s noncompliance with the Nondiscrimination provisions of this contract, the Recipient will impose such contract sanctions as it or the FHWA may determine to be appropriate, including, but not limited to:

1. withholding payments to the contractor under the contract until the contractor complies; and/or

2. cancelling, terminating, or suspending a contract, in whole or in part.

6. Incorporation of Provisions: The contractor will include the provisions of paragraphs one through six in every subcontract, including procurements of materials and leases of equipment, unless exempt by the Acts, the Regulations and directives issued pursuant thereto. The contractor will take action with respect to any subcontract or procurement as the Recipient or the FHWA may direct as a means of enforcing such provisions including sanctions for noncompliance. Provided, that if the contractor becomes involved in, or threatened with litigation by a subcontractor, or supplier because of such direction, the contractor may request the Recipient to enter into any litigation to protect the interests of the Recipient. In addition, the contractor may request the United States to enter into the litigation to protect the interests of the United States.
33 APPENDIX B

CLAUSES FOR DEEDS TRANSFERRING UNITED STATES PROPERTY
The following clauses will be included in deeds effecting or recording the transfer of real property, structures, or improvements thereon, or granting interest therein from the United States pursuant to the provisions of Assurance 4:

NOW THEREFORE, the U.S. Department of Transportation as authorized by law and upon the condition that the California Department of Transportation will accept title to the lands and maintain the project constructed thereon in accordance with Title 23 U.S.C., the regulations for the administration of the preceding statute, and the policies and procedures prescribed by the FHWA of the U.S. Department of Transportation in accordance and in compliance with all requirements imposed by Title 49, Code of Federal Regulations, U.S. Department of Transportation, Subtitle A, Office of the Secretary, Part 21, Nondiscrimination in Federally-assisted programs of the U.S. Department of Transportation pertaining to and effectuating the provisions of Title VI of the Civil Rights Act of 1964 (78 Stat. 252; 42 U.S.C. § 2000d to 2000d-4), does hereby remise, release, quitclaim and convey unto the California Department of Transportation all the right, title and interest of the U.S. Department of Transportation in and to said lands described in Exhibit A attached hereto and made a part hereof. (HABENDUM CLAUSE)
TO HAVE AND TO HOLD said lands and interests therein unto the California Department of Transportation and its successors forever, subject, however, to the covenants, conditions, restrictions and reservations herein contained as follows, which will remain in effect for the period during which the real property or structures are used for a purpose for which Federal financial assistance is extended or for another purpose involving the provision of similar services or benefits and will be binding on the California Department of Transportation, its successors and assigns.

The California Department of Transportation, in consideration of the conveyance of said lands and interest in lands, does hereby covenant and agree as a covenant running with the land for itself, its successors and assigns, that (1) no person will on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination with regard to any facility located wholly or in part on, over, or under such lands hereby conveyed [,] [and]* (2) that the California Department of Transportation will use the lands and interests in lands and interest in lands so conveyed, in compliance with all requirements imposed by or pursuant to Title 49, Code of Federal Regulations, U.S. Department of Transportation, Subtitle A, Office of the Secretary, Part 21, Nondiscrimination in Federally-assisted programs of the U.S. Department of Transportation, Effectuation of Title VI of the Civil Rights Act of 1964, and as said Regulations and Acts may be amended[, and (3) that in the event of breach of any of the above-mentioned non-discrimination conditions, the Department will have a right to enter or re-enter said lands and facilities on said lands, and that above described land and facilities will thereon revert to and vest in and become the absolute property of the U.S. Department of Transportation and its assigns as such interest existed prior to this instruction].* (*Reverter clause and related language to be used only when it is determined that such a clause is necessary in order to make clear the purpose of Title VI.) 34 APPENDIX C

CLAUSES FOR TRANSFER OF REAL PROPERTY ACQUIRED OR IMPROVED UNDER THE

ACTIVITY, FACILITY, OR PROGRAM
The following clauses will be included in deeds, licenses, leases, permits, or similar instruments entered into by the California Department of Transportation pursuant to the provisions of Assurance 7(a):

A. The (grantee, lessee, permittee, etc. as appropriate) for himself/herself, his/her heirs, personal representatives, successors in interest, and assigns, as a part of the consideration hereof, does hereby covenant and agree [in the case of deeds and leases add “as a covenant running with the land”] that:

1. In the event facilities are constructed, maintained, or otherwise operated on the property described in this (deed, license, lease, permit, etc.) for a purpose for which a U.S. Department of Transportation activity, facility, or program is extended or for another purpose involving the provision of similar services or benefits, the (grantee, licensee, lessee, permittee, etc.) will maintain and operate such facilities and services in compliance with all requirements imposed by the Acts and Regulations (as may be amended) such that no person on the grounds of race, color, or national origin, will be excluded from participation in, denied the benefits of, or be otherwise subjected to discrimination in the use of said facilities.

B. With respect to licenses, leases, permits, etc., in the event of breach of any of the above Nondiscrimination covenants, the California Department of Transportation will have the right to terminate the (lease, license, permit, etc.) and to enter, re-enter, and repossess said lands and facilities thereon, and hold the same as if the (lease, license, permit, etc.) had never been made or issued.* C. With respect to a deed, in the event of breach of any of the above Non-discrimination covenants, the California Department of Transportation will have the right to enter or re-enter the lands and facilities thereon, and the above described lands and facilities will there upon revert to and vest in and become the absolute property of the California Department of Transportation and its assigns.* (*Reverter clause and related language to be used only when it is determined that such a clause is necessary to make clear the purpose of Title VI.)
35 APPENDIX D

CLAUSES FOR CONSTRUCTION/USE ACCESS TO REAL PROPERTY ACQUIRED UNDER

THE ACTIVITY, FACILITY OR PROGRAM
The following clauses will be included in deeds, licenses, permits, or similar instruments/agreements entered into by the California Department of Transportation pursuant to the provisions of Assurance 7(b):

A. The (grantee, licensee, permittee, etc., as appropriate) for himself/herself, his/her heirs, personal representatives, successors in interest ,and assigns, as a part of the consideration hereof, does hereby covenant and agree (in the case of deeds and leases add, “as a covenant running with the land”) that (1) no person on the ground of race, color, or national origin, will be excluded from participation in, denied the benefits of, or be otherwise subjected to discrimination in the use of said facilities, (2) that in the construction of any improvements on, over, or under such land, and the furnishings of services thereon, no person on the ground of race, color, or national origin, will be excluded from participation in, denied the benefits or, or otherwise be subjected to discrimination, (3) that the (grantee, licensee, lessee, permittee, etc.) will use the premises in compliance with all other requirements imposed by or pursuant to the Acts and Regulations, as amended, set forth in this Assurance.

B. With respect to (licenses, leases, permits, etc.) in the event of breach of any of the above of the above Non-discrimination covenants, the California Department of Transportation will have the right to terminate the (license, permits, etc., as appropriate) and to enter or re-enter and repossess said land and the facilities thereon, and hold the same as if said (license, permit, etc., as appropriate) had never been made or issued.*
C. With respect to deeds, in the event of breach of any of the above Non-discrimination covenants, the California Department of Transportation will there upon revert to and vest in and become the absolute property of the California Department of Transportation and its assigns. (*Reverter clause and related language to be used only when it is determined that such a clause is necessary to make clear the purpose of Title VI.)
36 APPENDIX E
During the performance of this contract, the contractor, for itself, its assignees, and successors in interest (hereinafter referred to as the “contractor”) agrees to comply with the following non-discrimination statutes and authorities, including, but not limited to:

Pertinent Non-Discrimination Authorities:
• Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d et seq., 78 stat. 252), prohibits discrimination on the basis of race, color, national origin); and 49 CFR Part 21. • The Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, (42 U.S.C. § 4601), (prohibits unfair treatment of persons displaced or whose property has been acquired because of Federal or Federal-aid programs and projects); • Federal-Aid Highway Act of 1973, (23 U.S.C. § 324 et seq.), prohibits discrimination on the basis of sex;
• Section 504 of the Rehabilitation Act of 1973, (29 U.S.C. § 794 et seq.), as amended, (prohibits discrimination on the basis of disability); and 49 CR Part 27; • The Age Discrimination Act of 1975, as amended, (42 U.S.C. § 6101 et seq.), prohibits discrimination on the basis of age);
• Airport and Airway Improvement Act of 1982, (49 U.S.C. § 471, Section 47123), as amended, (prohibits discrimination based on race, creed, color, national origin, or sex); • The Civil Rights Restoration Act of 1987, (PL 100-209), (Broadened the scope, coverage and applicability of Title VI of the Civil Rights Act of 1964, The Age Discrimination Act of 1975 and Section 504 of the Rehabilitation Act of 1973, by expanding the definition of the terms “programs or activities” to include all of the programs or activities of the Federal-aid recipients, sub-recipients and contractors, whether such programs or activities are Federally funded or not); • Titles II and III of the Americans with Disabilities Act, which prohibit discrimination of the basis of disability in the operation of public entities, public and private transportation systems, places of public accommodation, and certain testing entities (42 U.S.C. §§ 12131 – 12189) as implemented by Department of Transportation regulations 49 C.F.R. parts 37 and 38; • The Federal Aviation Administration’s Non-discrimination statute (49 U.S.C. § 47123) (prohibits discrimination on the basis of race, color, national origin, and sex); • Title IX of the Education Amendments of 1972, as amended, which prohibits you from discriminating because of sex in education programs or activities (20 U.S.C. 1681 et seq).