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Title VI Policy

Title VI Plan
For the Federal Transit Administration

TITLE VI COMPLAINT PROCEDURES

What is Title VI of the Civil Rights Act of 1964?
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color and national origin in programs and activities receiving Federal financial assistance.

Link Transit is committed to ensuring that no person is excluded from participation in, or denied the benefits of its transit services on the basis of race, color, or national origin, as protected by Title VI in Federal Transit Administration (FTA) Circular 4702.1.A  If you believe you have been subjected to discrimination under Title VI, you may file a complaint.

How to file a Title VI Complaint with Link Transit
You may file a signed, written complaint up to one hundred and eighty (180) days from the date of alleged discrimination.  The complaint should include the following information:

  • Your name, mailing address, and how to contact you (i.e., telephone number, email address, etc.)
  • How, when, where and why you believe you were discriminated against. Include the location, names and contact information of any witnesses.
  • Other information that you deem significant


To obtain additional information about your rights under Title VI or to file a complaint, contact:
Link Transit
Title VI Coordinator
2700 Euclid Avenue
Wenatchee, WA   98801
By phone:  509-664-7620
By Facsimile:  509-664-6486

NOTE:   Link Transit encourages all complainants to certify all mail that is sent through the U.S. Postal Service and/or ensure that all written correspondence can be tracked easily.  For complaints originally submitted by facsimile, an original, signed copy of the complaint must be mailed to the Title VI Coordinator as soon as possible, but no later than 180 days from the alleged date of discrimination.

What happens to my complaint after it is submitted to Link Transit?
All complaints alleging discrimination based on race, color or national origin in a service or benefit provided by Link Transit will be directly addressed by Link Transit.  Link Transit shall also provide appropriate assistance to complainants, including those persons with disabilities, or who are limited in their ability to communicate in English.  Additionally, Link Transit shall make every effort to address all complaints in an expeditious and thorough manner.

In instances where additional information is needed for investigation of the complaint, Link Transit will contact the complainant in writing.  Please note that in responding to any requests for additional information, a complainant's failure to provide the requested information may result in the administrative closure of the complaint.

Once sufficient information for investigating the complaint is received by Link Transit, a written response will be drafted subject to review by the transit's attorney.   If appropriate, Link Transit's attorney may administratively close the complaint.  In this case, Link Transit will notify the complainant of the action as soon as possible. 

How will I be notified of the outcome of my complaint?
Link Transit will send a final written response to the complainant and advise the complainant of his or her right to 1) appeal within 7 calendar days of receipt of the final written decision from Link Transit, and/or 2) file a complaint externally with the U.S. Department of Transportation and/or the Federal Transit Administration.  Every effort will be made to respond to Title VI complaints within 60 working days of receipt of such complaints, if not sooner.


To date, there have been no Title VI investigations, complaints or lawsuits.

LIMITED ENGLISH PROFICIENCY (LEP) PLAN
Link Transit is committed to breaking down language barriers by implementing consistent standards of language assistance across its service area.
Census.  The United States is home to millions of national origin minority individuals who are LEP. That is, their primary language is not English and they cannot speak, read, write or understand the English language at a level that permits them to interact effectively with recipients of Federal financial assistance.  Because of language differences and the inability to effectively speak or understand English, persons with LEP may be subject to exclusion from programs or activities, experience delays or denials of services.  These individuals may be entitled to language assistance with respect to a particular type of service.  The federal government and those receiving assistance from the federal government must take reasonable steps to ensure that LEP persons have meaningful access to the programs, services, and information those entities provide. This will require agencies to establish creative solutions to address the needs of this ever-growing population of individuals, for whom English is not their primary language.  According to the 2000 Census Data for Chelan and Douglas Counties, English is spoken by 80.37% of Chelan County and 80.5% of Douglas County.  Overwhelmingly, Spanish represents 18.02% of the non English speaking Chelan County and 17.5% of the non English speaking Douglas County.

ANALYSIS OF FACTORS
Factor No. 1:  The nature and importance of service provided by Link Transit.   Link Transit provides important transit services to the public through its fixed route, paratransit, and rideshare programs.
Factor No. 2:  The number or proportion of LEP persons in the service area.  Link Transit's jurisdiction covers two broad areas:  Chelan and Douglas Counties which are largely English speaking. 19.63% of the residents of Chelan County speak languages other than English.  19.5% of Douglas County speaks languages other than English, 17.5% of them speaking Spanish.  The vast majority of the population with which we do business (individuals wishing to ride transit) is proficient in English, so that LEP services are not normally required.  No information was available regarding the percentage of bilingual residents of the counties.

Factor No. 3.  The frequency with which LEP individuals come into contact with the service.  All contacts with Link Transit are made through its offices located in Wenatchee, WA.  We serve LEP persons daily via our buses, contracted services, paratransit, demand response services, and vanpool.  The Guest Services Representatives speak Spanish and translate in person or over the phone a total of approximately 8 times a day.  While we do not track which calls or in person visits are from LEP individuals, we do track how many calls come in on our language line.  We have an average of 8 calls a month that require translations when Spanish speaking employees are unavailable and had no calls for languages other than Spanish by the people at the "Language Line". 

Factor No. 4.  The resources available to the recipient of the federal funds to assure meaningful access to the service by LEP persons.   Link Transit's current in-house language capabilities are Spanish and English.  Experienced staff is fluent in these languages. They have agreed to serve as interpreters as needed on those occasions when a person with limited English proficiency contacts the transit system.   The transit system also recognizes the need to have language services in other languages besides Spanish and has implemented a Language Line service to address that need.  Additionally, Link Transit has an outreach program where Spanish-speaking customers are taught how to ride the bus through training and through one-on-one assistance.   And finally, Link Transit has a number of publications in both English and Spanish.  We budget $10,000 per year to print route schedules in English and in Spanish.  We spend an additional $1,500 per year to produce English/Spanish language flyers for Trolley services.  Special notices of public meetings and other events are made available in Spanish.  In 2008, we will spend a minimum of $15,000 in Spanish language print and television advertising.  We budgeted $1,300 in 2008 for "Language Line" services.
IMPLEMENTATION PLAN
Link Transit currently has implemented its plan and will review it annually, including any contacts with the LEP persons to determine the frequency of contacts, the language used, and how the contacts were handled.  We identify LEP persons in the service area by ridership, telephone contact counts, neighborhood demographics, general awareness surveys and board surveys.   We employ two Customer Service Representatives and one Guest Services Supervisor.  One of the Guest Services Representatives speaks Spanish.  We have recently hired Spanish speaking individuals who are training to be Dispatchers for fixed route and paratransit services.  Our Executive Assistant/Clerk of the Board is bilingual and available to help with Spanish speaking customers.   Employees in several departments have representatives that are trained on the "Language Line".   Timetables in bus schedules are printed in Spanish.  Link Transit's Title VI policy and a Complaint Form are available on our website.  Beginning in 2009, all printed maps and schedules will have Title VI language.  And we are working to improve travel training services for Spanish-speaking individuals.   If there is a service change, we run notices in the newspaper in Spanish and in English.  We also have flyers on the bus which are printed as the information changes (not at any particular time but rather as route, schedule or fare information changes or when we run out of flyers.  In order to comply with 49 CFR 21.9(d), Link Transit and its subrecipients must provide information to beneficiaries regarding their Title VI obligations and inform beneficiaries of the protections against discrimination afforded them by Title VI.  LINK TRANSIT has established a statement of rights and a policy statement.

NOTIFYING BENEFICIARIES OF THEIR RIGHTS UNDER TITLE VI

1.    Our website includes our Title VI policy and complaint form.  The website will also state:

LINK TRANSIT does not discriminate on the basis of race, color or national origin.

LINK TRANSIT no descrimina en base de raza, color o origen nacional.

2.  Our Title VI policy and complaint form are also posted at our Operations and Maintenance Facility (located at 2700 Euclid Avenue, Wenatchee, WA) as well as at our intermodal center, Columbia Station (located at 300 South Columbia Street, Wenatchee, WA).  Individuals who believe they have been discriminated against may request a complaint form from our Guest Services staff at Columbia Station or from our Receptionist at our Operations Base.

INCLUSIVE PUBLIC PARTICIPATION

Community Outreach is a requirement of Title VI.  Recipients and subrecipients shall seek out and consider the viewpoints of minority and low-income populations in the course of conducting public outreach.  Recipients have wide latitude to determine what specific measures are most appropriate and should make this determination based on the composition of the affected population, the public involvement process, and the resources of Link Transit.   Link Transit has engaged the public in its planning and decision-making processes, as well as its marketing and outreach activities.   Between 2005-2008, the public was invited to participate in these activities:

Transit Development Plan (TDP). The Transit Development Plan is a requirement of the Washington State Legislature.  The Plan is prepared by the independent transit properties and turned into the State DOT.  A summary document is prepared which shows the size of the fleet, costs, revenue, service revenue hours, revenue miles, expense and capital expenditures.  Public hearings are held to obtain comments from the public on the TDP.

Transit Improvement Plan (TIP).  Another document called the Transit Improvement Plan is prepared and it is used by the cities and counties.  The TIP is a planning document that only addresses capital projects and improvement projects in cities and counties.   All TIPs from local jurisdictions (counties and cities) as well as the transits feed into a Regional TIP which is required by the federal government.  If an item we wish to purchase is not in the TIP, it cannot be funded.  TIP is only for capital projects and represents the capital section of the Transit Development Plan.  Although TIP is a federal requirement, it goes through the region and the state.  Public hearings are held to obtain comments from the public on the TIP.

Board Meetings.  The Board of Directors holds monthly meetings and the public is invited to attend.

Public Meetings.  When new service is proposed information is disseminated to the neighborhoods affected and public meetings are scheduled. 

Travel Training Class.  Link Transit has developed a travel training program to reach out to community groups (senior centers, senior facilities, the disabled community) to conduct travel training classes.  Travel Training classes are ongoing as well as outreach to these populations.

Customer Complaint Process.   Citizens may call our Guest Services Department at 509-662-1155 to lodge a complaint or comment.  All complaints/comments are input into a database and then distributed to the relevant manager who researches the complaint and responds back to the citizen.  Link Transit's complaint process was updated in 2007-2008.

General Awareness and Phone Surveys.   We conduct onboard rider and general awareness surveys frequently.  In 2008 a marketing study was undertaken to garner information from the public regarding their perceptions of public transportation.  Origin/Destination surveys and other public surveys are developed to assist Link Transit in gathering information to develop new routes.  

Bilingual Outreach.  Link Transit's Guest Services group provides Spanish-speaking guests with information on public transit services in Spanish.  Guest Services assistance is utilized in outreach programs and offered for programs and public meetings.

Title VI Plan For the Federal Transit Administration
 
TITLE VI COMPLAINT PROCEDURES

What is Title VI of the Civil Rights Act of 1964?
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color and national origin in programs and activities receiving Federal financial assistance.

Link Transit is committed to ensuring that no person is excluded from participation in, or denied the benefits of its transit services on the basis of race, color, or national origin, as protected by Title VI in Federal Transit Administration (FTA) Circular 4702.1.A  If you believe you have been subjected to discrimination under Title VI, you may file a complaint.

How to file a Title VI Complaint?
You may file a signed, written complaint thirty (30) days from the date of alleged discrimination.  The complaint should include the following information:

  • Your name, mailing address, and how to contact you (i.e., telephone number, email address, etc.)
  • How, when, where and why you believe you were discriminated against. Include the location, names and contact information of any witnesses.
  • Other information that you deem significant

The complaint may be filed in writing with Link Transit at the following address:

Click here to download the complaint form TITLE_VI_COMPLAINT_FORM

Link Transit
Title VI Coordinator
2700 Euclid Avenue
Wenatchee, WA   98801
By phone:  509-664-7620
By Facsimile:  509-664-6486

NOTE:   Link Transit encourages all complainants to certify all mail that is sent through the U.S. Postal Service and/or ensure that all written correspondence can be tracked easily.  For complaints originally submitted by facsimile, an original, signed copy of the complaint must be mailed to the Title VI Coordinator as soon as possible, but no later than 30 days from the alleged date of discrimination.

What happens to my complaint after it is submitted to Link Transit?
All complaints alleging discrimination based on race, color or national origin in a service or benefit provided by Link Transit will be directly addressed by Link Transit.  Link Transit shall also provide appropriate assistance to complainants, including those persons with disabilities, or who are limited in their ability to communicate in English.  Additionally, Link Transit shall make every effort to address all complaints in an expeditious and thorough manner.

In instances where additional information is needed for investigation of the complaint, Link Transit will contact the complainant in writing.  Please note that in responding to any requests for additional information, a complainant's failure to provide the requested information may result in the administrative closure of the complaint.

Once sufficient information for investigating the complaint is received by Link Transit, a written response will be drafted subject to review by the transit's attorney.   If appropriate, Link Transit's attorney may administratively close the complaint.  In this case, Link Transit will notify the complainant of the action as soon as possible. 

How will I be notified of the outcome of my complaint?
Link Transit will send a final written response to the complainant and advise the complainant of his or her right to 1) appeal within 7 calendar days of receipt of the final written decision from Link Transit, and/or 2) file a complaint externally with the U.S. Department of Transportation and/or the Federal Transit Administration.  Every effort will be made to respond to Title VI complaints within 60 working days of receipt of such complaints, if not sooner.

In addition to the complaint process described above, a complainant may file a Title VI complaint with the following offices:

Federal Transit Administration Office of Civil Rights               
Attention: Title VI Program Coordinator

East Building, 5th Floor - TCR
1200 New Jersey Avenue
Washington, DC   20590

RECORD OF TITLE VI INVESTIGATIONS,
COMPLAINTS OR LAWSUITS

To date, there have been no Title VI investigations, complaints or lawsuits.

LIMITED ENGLISH PROFICIENCY (LEP) PLAN
Link Transit is committed to breaking down language barriers by implementing consistent standards of language assistance across its service area.
Census.  The United States is home to millions of national origin minority individuals who are LEP. That is, their primary language is not English and they cannot speak, read, write or understand the English language at a level that permits them to interact effectively with recipients of Federal financial assistance.  Because of language differences and the inability to effectively speak or understand English, persons with LEP may be subject to exclusion from programs or activities, experience delays or denials of services.  These individuals may be entitled to language assistance with respect to a particular type of service.  The federal government and those receiving assistance from the federal government must take reasonable steps to ensure that LEP persons have meaningful access to the programs, services, and information those entities provide. This will require agencies to establish creative solutions to address the needs of this ever-growing population of individuals, for whom English is not their primary language.  According to the 2000 Census Data for Chelan and Douglas Counties, English is spoken by 80.37% of Chelan County and 80.5% of Douglas County.  Overwhelmingly, Spanish represents 18.02% of the non English speaking Chelan County and 17.5% of the non English speaking Douglas County.
ANALYSIS OF FACTORS
Factor No. 1:  The nature and importance of service provided by Link Transit.   Link Transit provides important transit services to the public through its fixed route, paratransit, and rideshare programs.
Factor No. 2:  The number or proportion of LEP persons in the service area.  Link Transit's jurisdiction covers two broad areas:  Chelan and Douglas Counties which are largely English speaking. 19.63% of the residents of Chelan County speak languages other than English.  19.5% of Douglas County speaks languages other than English, 17.5% of them speaking Spanish.  The vast majority of the population with which we do business (individuals wishing to ride transit) is proficient in English, so that LEP services are not normally required.  No information was available regarding the percentage of bilingual residents of the counties.

Factor No. 3.  The frequency with which LEP individuals come into contact with the service.  All contacts with Link Transit are made through its offices located in Wenatchee, WA.  We serve LEP persons daily via our buses, contracted services, paratransit, demand response services, and vanpool.  The Guest Services Representatives speak Spanish and translate in person or over the phone a total of approximately 8 times a day.  While we do not track which calls or in person visits are from LEP individuals, we do track how many calls come in on our language line.  We have an average of 8 calls a month that require translations when Spanish speaking employees are unavailable and had no calls for languages other than Spanish by the people at the "Language Line". 

Factor No. 4.  The resources available to the recipient of the federal funds to assure meaningful access to the service by LEP persons.   Link Transit's current in-house language capabilities are Spanish and English.  Experienced staff is fluent in these languages. They have agreed to serve as interpreters as needed on those occasions when a person with limited English proficiency contacts the transit system.   The transit system also recognizes the need to have language services in other languages besides Spanish and has implemented a Language Line service to address that need.  Additionally, Link Transit has an outreach program where Spanish-speaking customers are taught how to ride the bus through training and through one-on-one assistance.   And finally, Link Transit has a number of publications in both English and Spanish.  We budget $10,000 per year to print route schedules in English and in Spanish.  We spend an additional $1,500 per year to produce English/Spanish language flyers for Trolley services.  Special notices of public meetings and other events are made available in Spanish.  In 2008, we will spend a minimum of $15,000 in Spanish language print and television advertising.  We budgeted $1,300 in 2008 for "Language Line" services.
IMPLEMENTATION PLAN
Link Transit currently has implemented its plan and will review it annually, including any contacts with the LEP persons to determine the frequency of contacts, the language used, and how the contacts were handled.  We identify LEP persons in the service area by ridership, telephone contact counts, neighborhood demographics, general awareness surveys and board surveys.   We employ two Customer Service Representatives and one Guest Services Supervisor.  One of the Guest Services Representatives speaks Spanish.  We have recently hired Spanish speaking individuals who are training to be Dispatchers for fixed route and paratransit services.  Our Executive Assistant/Clerk of the Board is bilingual and available to help with Spanish speaking customers.   Employees in several departments have representatives that are trained on the "Language Line".   Timetables in bus schedules are printed in Spanish.  Link Transit's Title VI policy and a Complaint Form are available on our website.  Beginning in 2009, all printed maps and schedules will have Title VI language.  And we are working to improve travel training services for Spanish-speaking individuals.   If there is a service change, we run notices in the newspaper in Spanish and in English.  We also have flyers on the bus which are printed as the information changes (not at any particular time but rather as route, schedule or fare information changes or when we run out of flyers.  In order to comply with 49 CFR 21.9(d), Link Transit and its subrecipients must provide information to beneficiaries regarding their Title VI obligations and inform beneficiaries of the protections against discrimination afforded them by Title VI.  LINK TRANSIT has established a statement of rights and a policy statement.

NOTIFYING BENEFICIARIES OF THEIR RIGHTS UNDER TITLE VI

1.    Our website includes our Title VI policy and complaint form.  The website will also state:

LINK TRANSIT does not discriminate on the basis of race, color or national origin.

LINK TRANSIT no descrimina en base de raza, color o origen nacional.

INCLUSIVE PUBLIC PARTICIPATION

Community Outreach is a requirement of Title VI.  Recipients and subrecipients shall seek out and consider the viewpoints of minority and low-income populations in the course of conducting public outreach.  Recipients have wide latitude to determine what specific measures are most appropriate and should make this determination based on the composition of the affected population, the public involvement process, and the resources of Link Transit.   Link Transit has engaged the public in its planning and decision-making processes, as well as its marketing and outreach activities.   Between 2005-2008, the public was invited to participate in these activities:

Transit Development Plan (TDP). The Transit Development Plan is a requirement of the Washington State Legislature.  The Plan is prepared by the independent transit properties and turned into the State DOT.  A summary document is prepared which shows the size of the fleet, costs, revenue, service revenue hours, revenue miles, expense and capital expenditures.  Public hearings are held to obtain comments from the public on the TDP.

Transit Improvement Plan (TIP).  Another document called the Transit Improvement Plan is prepared and it is used by the cities and counties.  The TIP is a planning document that only addresses capital projects and improvement projects in cities and counties.   All TIPs from local jurisdictions (counties and cities) as well as the transits feed into a Regional TIP which is required by the federal government.  If an item we wish to purchase is not in the TIP, it cannot be funded.  TIP is only for capital projects and represents the capital section of the Transit Development Plan.  Although TIP is a federal requirement, it goes through the region and the state.  Public hearings are held to obtain comments from the public on the TIP.

Board Meetings.  The Board of Directors holds monthly meetings and the public is invited to attend.

Public Meetings.  When new service is proposed information is disseminated to the neighborhoods affected and public meetings are scheduled. 

Travel Training Class.  Link Transit has developed a travel training program to reach out to community groups (senior centers, senior facilities, the disabled community) to conduct travel training classes.  Travel Training classes are ongoing as well as outreach to these populations.

Customer Complaint Process.   Citizens may call our Guest Services Department at 509-662-1155 to lodge a complaint or comment.  All complaints/comments are input into a database and then distributed to the relevant manager who researches the complaint and responds back to the citizen.  Link Transit's complaint process was updated in 2007-2008.

General Awareness and Phone Surveys.   We conduct onboard rider and general awareness surveys frequently.  In 2008 a marketing study was undertaken to garner information from the public regarding their perceptions of public transportation.  Origin/Destination surveys and other public surveys are developed to assist Link Transit in gathering information to develop new routes.  

Bilingual Outreach.  Link Transit's Guest Services group provides Spanish-speaking guests with information on public transit services in Spanish.  Guest Services assistance is utilized in outreach programs and offered for programs and public meetings.

 

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