Staff Report — Simi Valley City Council, September 8, 2025

CITY OF SIMI VALLEY

MEMORANDUM
S
eptember 8, 2025
T
O: City Council
F
ROM: Department of Public Works
SUBJECT: ADOPTION OF A RESOLUTION APPROVING THE CITY OF SIMI VALLEY 2025 FEDERAL HIGHWAY ADMINISTRATION TITLE VI

IMPLEMENTATION PLAN

STAFF RECOMMENDATION
It is recommended that the City Council adopt Resolution No. 2025-28 (page 3) approving the City of Simi Valley 2025 Federal Highway Administration (FHWA) Title VI Implementation Plan (Exhibit A, page 5).

BACKGROUND AND OVERVIEW
Title VI of the Civil Rights Act of 1964 protects people from discrimination based on race, color, and national origin in programs and activities receiving federal financial assistance.

The City of Simi Valley Title VI Program, adopted in May 2025, is tailored to the Federal Transit Administration (FTA), and while there are overlaps in the two plans' compliance requirements, the current plan does not meet all FHWA Title VI requirements.

T
itle VI compliance is a condition of receipt of federal funds. The City is committed to ensuring compliance with Title VI of the Civil Rights Act of 1964 and other non- discriminatory authorities, such that no person shall be excluded from participation in or be denied the benefits of any program or activity conducted by the City on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law.

FINDINGS AND ALTERNATIVES
As a condition of its grants, the FHWA requires that recipients have a Title VI Program adopted by its governing body every three years. The City’s adopted Title VI Program does not meet all FHWA regulations, and an implementation plan to comply with FHWA Title VI requirements is needed. To maintain funding eligibility, the City must review and update its Title VI Program to ensure compliance with FHWA regulations and then submit a Resolution of the City Council adopting its Title VI Program for the next three years.

T
he City contracted with Moore & Associates to create the City of Simi Valley 2025 FHWA Title VI Implementation Plan (Plan) to comply with FHWA Title VI requirements. The final draft of the Plan is attached as Exhibit A to the Resolution. Once approved, Moore & Associates will finalize the Plan for submission to the FHWA. This will include adding a narrative about any public or City Council discussion that occurred during the Council AGENDA ITEM NO.

Consent (6)

meeting, adding a copy of the adopted Resolution, updating the adoption date, and removing any “Draft” designations or watermarks. The Plan would be effective from September 30, 2025, through September 29, 2028.

The following alternatives are available to the City Council:

1. Adopt Resolution No. 2025-28 approving the City of Simi Valley 2025 FHWA Title VI Implementation Plan, direct staff to finalize the document for submission to the FHWA, and authorize the City Manager to sign; or

2. Direct staff to make modifications to the FHWA Title VI Implementation Plan, adopt Resolution No. 2025-28, and authorize the City Manager to sign; or

3. Do not approve the FHWA Title VI Implementation Plan, which would result in forfeiting access to federal funding.

Staff recommends Alternative No. 1

SUGGESTED CITY COUNCIL MOTION

I move to adopt Resolution No. 2025- 28 approving the City of Simi Valley 2025 FHWA Title VI Implementation Plan and authorize the City Manager to finalize and execute the necessary documents for submission to the FHWA.

SUMMARY

Title VI of the Civil Rights Act of 1964 protects people from discrimination based on race, color, and national origin in programs and activities receiving federal financial assistance.

As a condition of its grants, the FHWA requires that recipients have a Title VI Program adopted by its governing body every three years. The City’s adopted Title VI Program is FTA specific and does not meet all FHWA requirements. A delay in approving the Program may result in a delay in accessing awarded federal funds. Therefore, it is recommended that the City Council adopt R esolution No. 2025-28 approving the City of Simi Valley 2025 FHWA Title VI Implementation Plan, and authorize the City Manager to finalize and execute the necessary documents for submission to the FHWA.

____________________________________
Ronald K. Fuchiwaki
Public Works Director

Prepared by: Lauren Lien, Senior Engineer

INDEX Page

Resolution No. 2025-28 – FHWA Title VI Implementation Plan ....... 3 Exhibit “A” – City of Simi Valley’s Final Draft Title VI Program ......... 5 2 A2507.RES.MG

RESOLUTION NO. 2025-28

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

SIMI VALLEY APPROVING THE CITY OF SIMI VALLEY
2025 FEDERAL HIGHWAY ADMINISTRATION TITLE VI

IMPLEMENTATION PLAN

WHEREAS, the Secretary of Transportation is authorized to make grants for public transportation projects; and

WHEREAS, it is required by the U.S. Department of Transportation in accordance with the provisions of Title VI of the Civil Rights Act of 1964, in connection with the filing of an application for assistance under 49 U.S.C. Chapter 53, the applicant gives an assurance that it will comply with Title VI of the Civil Rights Act of 1964 and the U.S. Department of Transportation requirements thereunder; and

WHEREAS, the Federal Highway Administration (FHWA) requires an active Title VI Program; and

WHEREAS, the City Council seeks to adopt the City of Simi Valley’s 2025 FHWA Title VI Implementation Plan.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF SIMI VALLEY DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. The City Council approves the City of Simi Valley 2025 FHWA Title VI Implementation Plan attached hereto as Exhibit “A,” effective from September 30, 2025 through September 29, 2028.

SECTION 2. The City Manager is hereby authorized to execute and file with such applications an assurance, or any other documents required by the U.S.

Department of Transportation effectuating the purposes of Title VI of the Civil Rights Act of 1964.

SECTION 3. It is within the City’s mission to deliver excellent service to the community that is accessible, efficient, and accountable to its citizens.

SECTION 4. The City Clerk will certify to the adoption of this resolution and shall cause a certified resolution to be filed in the Office of the City Clerk.

3 PASSED and ADOPTED this 8th day of September 2025.

Attest:

Lucy Blanco, City Clerk Dee Dee Cavanaugh, Mayor of the City of Simi Valley, California

Approved as to Form: Approved as to Content:

Algeria R. Ford, City Attorney Samantha C. Argabrite, City Manager

Ronald K. Fuchiwaki
Public Works Director

4 RES. NO. 2025-28

EXHIBIT “A”

CITY OF SIMI VALLEY
2025 FEDERAL HIGHWAY ADMINISTRATION

TITLE VI IMPLEMENTATION PLAN
5 RES. NO. 2025-28
City of Simi Valley
2025 Federal Highway Administration Title VI
Implementation Plan

DRAFT FINAL REPORT
Developed July 2025
To be adopted by the City of Simi Valley City Council
September 8, 2025
Point of Contact
Risk Manager
C/O Human Resources
City of Simi Valley
2929 Tapo Canyon Road
Simi Valley, CA 93063
(805) 583-6336
[email protected]
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2 Table of Contents

Section 1. Non-Discrimination Policy Statement .................................................. 3 Section 2. Non-Discriminatory Legislation ............................................................ 4 Section 3. Organization Structure .......................................................................... 5 Section 4. Title VI Complaint Procedures ............................................................. 7 Section 5. Title VI Outreach and Resources .......................................................... 9 Section 6. Data Collection and Analysis.............................................................. 10 Section 7. Contract Documents and Agreements............................................... 10 Section 8. Training ................................................................................................ 11 Section 9. Annual Work Plan ................................................................................ 11 Appendix A. Four-Factor Analysis and Limited English Proficiency Plan ............... 12 Appendix B. Notice to the Public ......................................................................... 15 Appendix C. Title VI Complaint Forms ................................................................ 16 Appendix D. US DOT Title VI Assurances A-E .................................................... 20

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3 Section 1. Non-Discrimination Policy Statement

The City of Simi Valley Public Works Department is committed to ensuring compliance with Title VI of the Civil Rights Act of 1964 and other non-discriminatory authorities, such that no person shall be excluded from participation in or be denied the benefits of any program or activity conducted by the City of Simi Valley Public Works Department on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law.

Further, no person shall be subjected to discrimination under any program or activity conducted by the City of Simi Valley Public Works Department, on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law.

Title VI compliance is a condition of receipt of federal funds. The Title VI Coordinator is authorized to ensure compliance with this policy, Title VI of the Civil Rights Act of 1964, 42 U.S.C § 2000d and related statutes, and the requirements of 23 Code o f Federal Regulation (CFR) pt. 200 and 49 CFR pt. 21.

Samantha C. Argabrite Date
City Manager, City of Simi Valley

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4 Section 2. Non-Discriminatory Legislation

Title VI of the Civil Rights Act of 1964 – Provides that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination, under any program or activity receiving Federal financial assistance (as implemented through 23 CFR 200.9 and 49 CFR 21).

Section 162(a) of the Federal -Aid Highway Act of 1973 (Section 324, Title 23 U.S.C.) – Prohibits discrimination on the basis of sex by recipients and sub -recipients of Federal financial assistance.

Section 504 of the Rehabilitation Act of 1973 – Prohibits discrimination on the basis of disability by recipients and sub-recipients of Federal financial assistance.

The Age Discrimination Act of 1975 (Section 6101 -6107, Title 42 U.S.C.) – 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 200 -209) – Clarifies that the original intent of Congress in Title VI of the Civil Rights Act of 1964, Title IX of the Educational Amendments of 1972, the Age Discrimination Act of 1975, and Section 504 of the Rehabilitation Act of 1973 was to apply the non-discrimination statutes to all programs and activities of Federal- aid recipients, sub-recipients, contractors and vendors, whether all such programs are federally assisted or not.

Executive Order 12898 (issued February 11, 1994) – Addresses Environmental Justice regarding minority and low -income populations and requires agencies to develop strategies to address disproportionately high and adverse human health or environmental effects of their programs on minority and low -income popu lations; promote nondiscrimination in federal programs substantially affecting human health and the environment; and provide minority and low-income communities access to public information and an opportun ity for public participation in matters relating to human health or the environment.

Executive Order 13166 (issued August 16, 2000) – Addresses improved access to services for persons with limited English proficiency. Agencies are directed to evaluate services provided and implement a system that ensures that Limited English Proficiency (LEP) persons are able to meaningfully access the services provided consistent with, and without unduly burdening, the fundamental mission of the local agency. Agencies are directed to ensure that recipients of federal financial assistance provide meaningful access to program, services and information to their LEP applicants and beneficiaries free of charge.
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5 Section 3. Organization Structure

The City of Simi Valley’s Title VI program is a multi-tiered program in which multiple roles work toward the ultimate goal of assuring full compliance with the provisions of Title VI of the Civil Rights Act of 1964 and related statutes. The City has assigned the role of Title VI Coordinator to the City’s Risk Manager. The role and responsibilities are as follows:

Title VI Coordinator
• Ensures that City’s Title VI program up -to-date with all requirements set forth by the Federal Highway Administration (FHWA), California Department of Transportation (Caltrans), and any other applicable jurisdictions.
• Maintains open line of communication with City Manager, City Council, and other City leadership positions as necessary to facilitate the Title VI Program requirements in a timely manner.
• Directs staff to coordinate and attend trainings, prepare required reports, create and distribute Title VI information for the public, and manage complaints per the Program’s direction.
• Prepares and coordinates Title VI Plan and Annual Report submission. • Develops Title VI information for dissemination to public. • Ensures that Title VI Assurances have been incorporated into all Federal -aid Contracts and Agreements.
• Develops and coordinates Title VI training for managers, supervisors and staff with frequent public contract, on a two-year minimum basis.
• Develops procedures for collection and analysis of statistical data of participants in, and beneficiaries of federally funded roadway projects. • Analyzes data collected to determine effectiveness of outreach methods to avoid group exclusion, and encourage group participation.
• Develops complaint procedures, complaint log, and ensures that all applicable staff are properly trained in the complaint reporting procedures. • Attends trainings as to maintain knowledge of current Title VI requirements. • Reports complaints through complaint procedure listed as part of City’s Title VI Implementation Plan.
• Incorporates required Title VI language into Federal-aid contracts and agreements.

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6 Title VI Organization Chart

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7 Section 4. Title VI Complaint Procedures

The City of Simi Valley Public Works Department is committed to ensuring compliance with Title VI of the Civil Rights Act of 1964 and other non -discriminatory authorities, such that no person shall be excluded from participation in or be denied the benefits of any program or acti vity conducted by the City of Simi Valley Public Works Department on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law.

Any person that believes they have been discriminated against on the grounds of race, color, national origin, sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law by the City of Simi Valley’s Public Works Department, its contractors, consultants or any other party that acts on behalf of the Public Works Department may file a Title VI complaint by completing and submitting the City’s Title VI Complaint Form (Appendix C), which can be fou nd displayed in the City Hall lobby and online at https://www.simivalley.org/departments/public-works/public-works-documents.

The City of Simi Valley's Title VI Complaint Form ( Appendix C) may be used to detail the complaint, but is not mandatory. Complaint forms may also be obtained by calling (805) 583-6336.

The City will provide appropriate assistance to complainants who are limited in their ability to communicate in English. Written complaints may be sent to:

Title VI Coordinator/Risk Manager
C/O Human Resources
City of Simi Valley
2929 Tapo Canyon Road
Simi Valley, CA 93063
[email protected]

The City’s Title VI Coordinator processes complaints received no more than 180 days after the alleged incident. The Title VI Coordinator will only process complaints that are complete, which include at a minimum, the following:

• Complainant’s contact information
• Date of alleged act of discrimination
• Details of the alleged discrimination
• The complainant’s signature

Once the Title VI complaint is received, the Title VI Coordinator will forward the complaint to Caltrans, to be submitted to the FHWA Division Office. The Title VI Coordinator will also begin processing the complaint by entering said complaint into the City’s Title VI Discrimination Complaint Log and conducting an internal investigation. Once a finding has been determined/received, the City’s Title VI Coordinator will provide said finding to the complainant within ten business days via letter and/or email.

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8 Title VI Complaints Processed Under the Federal Highway Administration (FHWA)

Title VI complaints filed with Caltrans in which Caltrans is named as the Respondent will be forwarded to the FHWA Division Office. The Complainant will receive an acknowledgement letter informing them that the complaint has been received and forwarded to the FHWA.

Per the FHWA Guidance Memorandum, Processing of Title VI Complaints, dated June 13, 2018, all Title VI complaints received by a sub -recipient (e.g., the City of Simi Valley) are to be forwarded to Caltrans to be submitted to the FHWA California Division Office. If FHWA’s Headquarters Office of Civil Rights (HCR) determines a Title VI complaint against a sub-recipient can be investigated by Caltrans, HCR may delegate the task of investigating the complaint to Caltrans.

Caltrans Office of Civil Rights (OCR) Investigation Process

If OCR is delegated the responsibility of performing an investigation, OCR has 90 days to investigate the complaint. If additional time is needed, OCR will call the complainant and inform them.

If more information is needed to resolve the case, the OCR investigator may contact the complainant. The complainant has ten business days from the date of the letter to send the requested information to the investigator assigned to the case.

If the investigator is not contacted by the complainant or does not receive the additional information within ten business days, OCR can administratively close the case. A case can also be administratively closed if the complainant no longer wishes to pursue their case.

OCR will consult with HCR regarding the disposition of the complaint. HCR will undertake disposition of the complaint through either (1) informal resolution or (2) issuance of a Letter of Finding of compliance or noncompliance with Title VI. A copy of the Letter of Finding will be sent to all parties via the FHWA California Division Office.

A person may also file a complaint directly with the FHWA or Caltrans using the following contact information:

Federal Highway Administration California Department of Transportation U.S. Department of Transportation Office of Civil Rights Office of Civil Rights Attention: Title VI Program Branch 1200 New Jersey Avenue, SE 1823 14th Street, MS 79
8th Floor E81-105 Sacramento, CA 95811
Washington, DC 20590 [email protected]

Should a complaint be filed with Simi Valley Public Works and one with a federal or state agency simultaneously, the federal/state complaint will supersede the City’s complaint and the City’s complaint procedures will be suspended pending the federal/state agency’s findings.

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9 Section 5. Title VI Outreach and Resources

Table 1: Languages Spoken at Home by Simi Valley Residents City of Simi Valley
Population Percent
of Total
Total Speak Only English 88,545 73.7%
Total Speak Language Other than English 31,561 26.3%
Total Speak English "very well" 20,611 17.2%
Total Speak English less than "very well" 10,950 9.1%
Speak English less than "very well" – Detail
Spanish 6,788 5.7%
Other Indo-European Languages 1,428 1.2%
Chinese 753 0.6%
Other Asian and Pacific Islander Languages 487 0.4%
Vietnamese 426 0.4%
Tagalog 417 0.4%
Russian, Polish, or Other Slavic Languages 166 0.1%
Korean 145 0.1%
Arabic 68 0.1%
German or Other West Germanic Languages 34 0.1%
French, Haitian, or Cajun 4 0.0%
Other and Unspecified Languages 234 0.2%
Source: 2023 American Community Survey 5-Year Estimates, Tables S1601 and C16001.

Limited English Proficiency
A Limited English Proficient (LEP) person is a person that does not speak English as a primary language and has a limited ability to read, write, or comprehend English. Per Executive Order 13166, agencies which receive Federal funding must examine their Federally -funded services and develop and implement processes that will allow LEP perso ns to meaningfully access said services. Executive Order 13166 also requires that agencies receiving Federal funding must establish guidance for providing meaningful access to LEPs, prepare a plan to overcome language barriers in Federally-funded programs and activities, and ensure that stakeholders have adequate opportunity to provide input.

As shown in Table 1 above, 9.1 percent of residents in Simi Valley are considered LEP persons, with the majority of those LEP persons primarily speaking Spanish (5.7 percent of residents) and Other Indo-European Languages (1.2 percent of residents). As outlined in the City’s LEP Plan (Appendix A), the City has conducted an LEP Needs Assessment, using a Four Factor Analysis to identify need and provide access to the LEP community in compliance with Executive Order 13166.

Title VI Information Dissemination
In order to ensure that Title VI and related Civil Rights information is readily available to the public, the City will develop public notices consisting of notices and complaint forms available in English and Spanish. The languages selected for the informational materials were based upon language data provided from the U.S. Census; see Table 1 above. Said notices will be placed in the City Hall lobby, in a highly visible and accessible location. The public notices and complaint forms will also be available for viewing on the City’s website at https://www.simivalley.org/departments/public-works/public-works-documents. 14 RES. NO. 2025-28
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10 Environmental Justice
In accordance with Executive Order 12898 (Federal Actions to Address Environmental Justice in Minority Populations and Low -Income Populations), City Staff will identify and address the environmental effects of programs, policies, and activities on minority and low-income populations for Federally -funded projects. Staff will consider demographic data during project design and involve the public in the planning and development process to assess the environmental impacts of projects on the community. The public’s input and demographic data analysis will enable staff to develop measures to mitigate any potential adverse effects on minority and low -income populations.

Section 6. Data Collection and Analysis

Demographic and related data collected and used by City staff comes from governmental sources responsible for collecting and vetting the information for consistency and accuracy. These sources include, but are not limited to, the U.S. Bureau of Labor Statics, U.S. Census Bureau, U.S. Bureau of Economic Analysis, California Department of Finance, California Department of Labor, and the California Employment Development Department.

Additionally, staff may also collect project -specific demographic data utilizing data collection as appropriate through the public outreach process on Federally funded projects. Such outreach that may give staff the opportunity to collect demographic data may include door hangers, posters, emails, social media releases, press releases to local newspaper, public meetings, virtual meetings, and public comment through websites generated for projects.

Section 7. Contract Documents and Agreements

The City’s Title VI Coordinator will ensure that any Federally-funded project documents contain the necessary Title VI Assurances and other language. Such assurances include, but may not be limited to:

• FHWA Form 1273 (Title VI and other non-discriminatory requirements) o Required on all FHWA contracts and subcontracts valued greater than $10,000 • Title VI Assurances Appendix A-E
o Appendix A-E to be attached to Federal-Aid contracts

Additionally, City staff will include the provisions indicated in the "Administering Agency – State Agreement for Federal-Aid Projects Master Agreement” in the Local Assistance Program Manual (LAPM) in contracts and agreements, where applicable, between the City and contractors.

The City will continue to utilize the "Local Agency Construction Contract Administration Checklist" (Exhibit 15-A of the LAPM), which confirms that DBE and labor/Equal Employment Opportunity (EEO) compliance requirements are performed and documented in the project files.

Exhibit 15-A of the LAPM documents that the local agency will meet all the requirements prior to the award of a construction contract.

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11 Lastly, the City will continue to utilize the "Resident Engineer’s Construction Contract Administration Checklist" (Exhibit 15-B of the LAPM) on federal-aid projects. The checklist assists in administering federal -aid highway construction projects and provides a record that the EEO/Wage Rate/False Statements posters are being posted at specific locations that employee interviews will be conducted in accordance with the Labor Compliance/EEO interview form, and that DBE requirements are met. City staff will continue to submit Exhibit 15-B, along with the Award Package shortly after award of the construction contract.

Section 8. Training

The City of Simi Valley Public Works Department will provide Title VI and related statute training to Public Works managers, supervisors, and staff with frequent public contact in the administration of federal-aid programs. These trainings will occur at minimum every two years, and within six months of hiring a new employee. The trainings will be conducted by the Title VI Coordinator, online through presentations, or through trainings hosted by Caltrans. Additionally, links to Caltrans, FHWA, and other applicable agency resources for Title VI and related statutes will be posted on the City’s website at https://www.simivalley.org/departments/public-works/public- works-documents.

In particular, the following items will be covered in trainings:

• Review of Simi Valley’s Title VI Implementation Plan and other relevant documents • Language assistance services offered for public use
• How to handle potential complaints
• Where to seek assistance for Title VI questions and concerns

Section 9. Annual Work Plan

The City of Simi Valley Public Works Department will annually establish and monitor program goals and accomplishments. The Title VI Coordinator will ensure that employee training is conducted, language translation services continue to be available, public participation is optimal, and appropriate Title VI signage is posted. This also includes updating community statistics and corresponding with state and federal agencies as necessary.

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12 Appendix A. Four-Factor Analysis
and Limited English Proficiency Plan

Background
Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency” requires that Federal agencies work to ensure that the recipients of Federal financial assistance provide meaningful access to their Limited English Proficiency (LEP) applicants and beneficiaries.

As such, local agencies are required to ensure that Federally funded programs and activities normally provided in English are accessible to LEP Persons. Each local agency shall perform an annual assessment to determine if modifications are needed to their programs and activities to ensure meaningful access by LEP persons. The assessment which is referred to as a “Four - Factor” analysis is based on the following factors:

1. The number or proportion of LEP persons eligible to be served or likely to be encountered.

2. The frequency of LEP contacts.

3. The nature and importance of the programs, services, or activities provided by the City of Simi Valley.

4. The resources available for LEP persons.

Simi Valley's total population is 125,100, with 120,106 individuals being age five years and over.

Of that number, a total of 10,950 persons (9.1 percent) are identified as having Limited English Proficiency. Of these persons 6, 788 (5.7 percent) speak Spanish; 7 53 speak Chinese (0.6 percent), 426 (0.4 percent) speak Vietnamese; 417 speak Tagalog (0.4 percent), 487 speak other Asian and Pacific Islander languages (0. 4 percent), and 1, 428 speak other Indo -European languages (1.2 percent). (These last two groups include multiple languages, and as a result are not considered under the Safe Harbor guidelines.)

Four-Factor Analysis

1. The number or proportion of LEP persons eligible to be served or likely to be encountered.

As shown in Table 1 below, Simi Valley has approximately 120,100 residents age five and older. 10,950 (9.1 percent) of Simi Valley residents are considered LEP persons, with the majority of those LEP persons primarily speaking Spanish (6,788, or 5.7 percent) and Other Indo-European Languages (1,428, or 1.2 percent). The remaining LEP individuals speak other languages, none of which comprises more than 0.6 percent of Simi Valley residents.

Changes to the data available through the American Community Survey have made it more difficult to identify potential LEP languages. For the 2023 ACS five -year estimates, only certain languages (including Spanish) are identified individually. All other languages are grouped into three broad categories: Other Asian and Pacific Islander Languages, Other Indo -European Languages, and All Other Languages. These broad categories include the following languages (among others):

• Other Asian and Pacific Islander Languages: Japanese, Hmong, Khmer, Thai, Lao, Samoan, Hawaiian, Telugu, Tamil, and Kannada.
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13 • Other Indo-European Languages: Italian, Portuguese, German, Yiddish, Greek, Serbo - Croatian, Ukrainian, Armenian, Persian/Farsi, Gujarati, Hindi, Urdu, Punjabi, Bengali, Nepali, and Marathi.
• All Other Languages: Navajo, other native languages of North America, Hebrew, Amharic, Somali, Yoruba, Igbo, Swahili, and Hungarian.

Based on English learner data from the Simi Valley Unified School District, languages under the grouping of Other Indo -European Languages most likely to be present in Simi Valley include Persian/Farsi, Punjabi, and Armenian. However, there is no evidence that any of these languages are prevalent enough to fall within the Safe Harbor guidelines.

2. The frequency of LEP contacts.

No data has been collected regarding frequency of contact with LEP persons at the City . Public Works staff does not regularly receive requests for translation through Federally funded programs/projects, though the outreach components of said programs/projects do typically have multilingual resources. Further, if translation services are neede d, the City utilizes a telephonic language interpretation service.

3. The nature and importance of programs, services, or activities provided by the City of Simi Valley.

From observation provided by Public Works staff, it is rare that translation services are requested for programs, services, or activities which are Federally funded. Staff are aware that more than nine percent of the City’s residents are LEPs and therefore it is highly likely that LEPs will be stakeholder in any FHWA-funded projects. As such, telephone language and in -person interpretation are provided as needed in support of these projects. 18 RES. NO. 2025-28
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14 4. The Resources Available for LEP persons.

The City has determined that resources for interpretation are readily available with respect to FHWA projects. However, the City is lacking with respect to documenting demographic data and conducting training. The City will also need to ensure Spanish -language noticing is provided for meetings, public outreach, and/or public hearings specific to FHWA-funded projects.

Action Plan
In order to ensure compliance with Title VI, and Executive Order 13166 the following publications and services will be made available for LEP person use:

• Non-Discrimination Policy Statement
o Statement shall be printed in English and Spanish. Said statement will be posted in the City Hall lobby in a highly visible location.
• Title VI Rights Poster
o Posters shall be printed in English and Spanish. Said posters will be posted in the City Hall lobby in a highly visible location, and additional copies will be available for the public to review and take.
• Title VI Complaint Form
o Complaint forms shall be printed in English and Spanish. Said forms will be in the City Hall lobby in a highly visible location.
• Title VI Webpage on City’s Website
o All of the City’s Title VI resources will be posted on the City’s website at the following link: https://www.simivalley.org/departments/public-works/public-works- documents.
• Future Planning and Projects
o The Public Works Department will ensure that all future projects and planning documents that are Federally funded utilize outreach methods that are compliant with Title VI and other related non-discriminatory assurances. o Additionally, the City will ensure that outreach materials are available in English and Spanish and that translators are readily available as necessary for any LEP Persons that would like to contribute or participate.

Lastly, the Title VI Coordinator will request an updated list of certified interpreter and translators from the Human Resources Department every six months, and distribute said list to those who are likely to encounter LEP persons, such that an interpreter or translator can be contacted when one is needed.

To ensure continuous compliance, the City will review the Title VI Implementation Plan and Limited English Proficiency Plan regularly, but at a minimum, as new data from the U.S. Census becomes available. As new regulations are created, the City will act promptly to update the existing plans and relevant resources.
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15 Appendix B. Notice to the Public

YOUR RIGHTS AGAINST DISCRIMINATION
UNDER TITLE VI OF THE CIVIL RIGHTS ACT OF 1964

AND RELATED NON-DISCRIMINATORY AUTHORITIES

Title VI of the Civil Rights Act of 1964 provides that no person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving federal financial assistance.

The following additional authorities provide protection against discrimination on the basis of sex, age, disability, religion, sexual orientation, gender identity, or any other category protected by State or Federal law:

Section 162(a) of the Federal-Aid Highway Act of 1973 (Section 324, Title 23 U.S.C.) Section 504 of the Rehabilitation Act of 1973
The Age Discrimination Act of 1975 (Section 6101-6107, Title 42 U.S.C.) The Civil Rights Restoration Act of 1987 (Public Law 200-209) Executive Order 12898 (issued February 11, 1994)
Executive Order 13166 (issued August 16, 2000)

Any person who believes that they have been discriminated against may file a written complaint with the City of Simi Valley Public Works Department, within 180 days of the alleged discrimination. Additional information and Title VI Complaint Forms can be obtained on the City of Simi Valley’s website at the following location: https://www.simivalley.org/departments/public- works/public-works-documents. Title VI Complaint Forms can also be obtained from the Public Works Department at City Hall.

To file a Title VI discrimination complaint, please use the following contact information:

Title VI Coordinator/Risk Manager
C/O Human Resources
City of Simi Valley
2929 Tapo Canyon Road
Simi Valley, CA 93063

[This notice to be provided in English and Spanish.]
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City of Simi Valley
16 Appendix C. Title VI Complaint Forms

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20 Appendix D. 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 Nondiscrimination in Federally -assisted programs of the U.S.

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

2. Non-discrimination: The contractor, with regard to the work performed by it during the contract, will not discriminate on the grounds of race, color, national origin, age, sex, or disability in the selection and retention of subcontractors, including procurements of materials and leases of equipment. The contractor will not participate directly or indirect ly 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 determi ned 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 Non - discrimination 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. 25 RES. NO. 2025-28
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City of Simi Valley
21 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 regulat ions 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, Non - discrimination in Federally-assisted programs of the U.S. Department of Transportation pertaining to and effectuating the provisions of Title VI of t he 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 [,] [an d]* (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 Tr ansportation, Subtitle A, Office of the Secretary, Part 21, Non - discrimination 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.) 26 RES. NO. 2025-28
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City of Simi Valley
22 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, den ied 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 Non - discrimination covenants, the California Department of Transportation will have the right to terminate the (lease, license, permit, etc.) and to enter, re -enter, and repossess said lands and facilities thereon, and hold the same as if the (lease, license, permit, etc.) had never been made or issued.*

C. With respect to a deed, in the event of breach of any of the above Nondiscrimination covenants, the California Department of Transportation will have the right to enter or re -enter the lands and facilities thereon, and the above described lands and facilities will there upon revert to and vest in and become the absolute property of the California Department of Transportation and its assigns.*

(*Reverter clause and related language to be used only when it is determined that such a clause is necessary to make clear the purpose of Title VI.)
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City of Simi Valley
23 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 Nondiscrimination covenants, the California Department of Transportation will there upon revert to and vest in and become the absolute property of the California Department of Transportation and its assigns.

(*Reverter clause and related language to be used only when it is determined that such a clause is necessary to make clear the purpose of Title VI.)
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City of Simi Valley
24 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);

• Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, which ensures discrimination against minority populations by discouraging programs, policies, and activities with disproportionately high and adverse human health or environmental effects on minority and low-income populations;

• Executive Order 13166, Improving Access to Services for Persons with Limited English Proficiency, and resulting agency guidance, national origin discrimination includes discrimination because of limited English proficiency (LEP). To ensure compliance with Title VI, you must take reasonable steps to ensure that LEP persons have meaningful access to your programs (70 Fed. Reg. at 74087 to 74100);

• Title IX of the Education Amendments of 1972, as amended, which prohibits you from discriminating because of sex in education programs or activities (20 U.S.C. 1681 et seq). 29 RES. NO. 2025-28

Simi Valley City CouncilSeptember 8, 2025

Simi Valley City Council
September 8, 2025