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Title VI Plan Cover Page



 

JO DAVIESS COUNTY TRANSIT/OPERATED BY THE WORKSHOP

2020

 

 

 

 

 

Title VI Contact: Jo Daviess County Transit director

Title VI Contact Phone: 815-777-8088

Jo Title VI Contact Email: jodaviesstransit@yahoo.com

TTY Number (If applicable): 800-526-0857

Address: 710 S. WEST STREET, GALENA, IL 61036

Web Address: www.jodaviesstransit.com

 

Title VI Plan Table of Contents

 

Title VI Plan Cover Page 1

Title VI Plan Table of Contents 2

Executive Summary 3

Non Discrimination Notice to the Public 4

Non Discrimination Notice to the Public - Spanish 5

Non Discrimination ADA/Title VI Complaint Procedures 6

Discrimination ADA/Title VI Complaint Form 8

Discrimination ADA/Title VI Investigations, Complaints, and Lawsuits 11

Public Participation Plan 12

Limited English Proficiency Plan 13

Non-elected Committees Membership Table 18

Monitoring for Subrecipient Title VI Compliance 18

Title VI Equity Analysis 19

Fixed Route Transit Provider Analysis 20

Board Approval for the Title VI Plan 21







 

Executive Summary

 

 

What type of program fund(s) did you apply for?

 

☐ 5310

☒ 5311

☐ Other (please explain)



 

Type of Funding Requests? (Check all that apply)

 

☒ Vehicle Funds

☒ Operating Funds

☐ Other (please explain)


 

Is your agency receiving direct funds from FTA? 

 

 ☐If yes, please attach a copy of your FTA letter of approval of Title VI Plan.

 

 ☒No

Non-Discrimination Notice to the Public


 

Notifying the Public of Rights Under Title VI and ADA

Jo Daviess County Transit, Operated by The Workshop

 

Jo Daviess County Transit, Operated by The Workshop operates its programs and services without regard to race, color, national origin or disability in accordance with Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act of 1990 (ADA). Any person who believes she or he has been aggrieved by any unlawful discriminatory practice under Title VI may file a complaint with the Jo Daviess County Transit, Operated by The Workshop.

 

For more information on the Jo Daviess County Transit, Operated by The Workshop’s civil rights program, and the procedures to file a complaint, contact Jo Daviess County Transit director, 815-777-8088, (TTY 800-526-0857); email jodaviesstransit@yahoo.com; or visit our administrative office at 710 S. WEST STREET, GALENA, IL 61036. For more information, visit www.jodaviesstransit.com

 

Complaints may be filed directly with the Illinois Department of Transportation (IDOT) Civil Rights Office.  ATTN: Title VI Program Coordinator 69 Washington Street Room 2100 Chicago, IL 60602 or with the Federal Transit Administration (FTA).  ATTN: Title VI Program Coordinator, 1200 New Jersey Ave., SE Washington DC 20590 

 

 

This notice is posted online at www.jodaviesstransit.com






 

Non-Discrimination Notice to the Public - Spanish

 

Aviso Público Sobre los Derechos Bajo el Título VI Y ADA

Jo Daviess County Transit, Operated by The Workshop

 

Jo Daviess County Transit, Operated by The Workshop (y sus subcontratistas, si cualquiera) asegura cumplir con el Título VI de la Ley de los Derechos Civiles de 1964, Sección 504 de la Ley de Rehabilitación de 1973 y La Ley de ciudadanos americanos con Discapacidades de 1990 (ADA).   El nivel y la calidad de servicios de transporte serán proveídos sin consideración a su raza, color, país de origen, o discapacidad. 

 

Para obtener más información sobre el programa de Derechos Civiles de Jo Daviess County Transit, Operated by The Workshop, y los procedimientos para presentar una queja, contacte Jo Daviess County Transit director 815-777-8088, (TTY 800-526-0857); o visite nuestra oficina administrativa en 710 S. WEST STREET, GALENA, IL 61036.  Para obtener más información, visite www.jodaviesstransit.com

 

Una queja puede ser presentada con la oficina de Derechos Civiles del Departamento de Transporte de Illinois (IDOT).  Atención: Title VI Program Manager, 69 W. Washington Street Chicago, IL 60602 o con la Administración Federal de Transporte (FTA).  Ate45nción: Title VI Coordinator, 1200 New Jersey Ave., SE Washington DC 2059

 

The above notice is posted in the following locations: Jo Daviess County Transit Building, Jo Daviess County Transit Buses and Vans. 

 

This notice is posted online at www.jodaviesstransit.com

Non-Discrimination ADA/Title VI Complaint Procedures

These procedures provide guidance for all complaints filed under Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, and the Americans with Disabilities Act of 1990 (ADA) as they relate to any program or activity that is administered by Jo Daviess County Transit, Operated by The Workshop including consultants, contractors and vendors. Intimidation or retaliation as a result of a complaint is prohibited by law. In addition to these procedures, complainants reserve the right to file a formal complaint with other State or Federal agencies or to seek private counsel for complaints alleging discrimination.  Every effort will be made to resolve complaints at the lowest possible level.

 

  1. Any person who believes he and/or she has been discriminated against on the basis of race, color, national origin, or disability may file a Discrimination complaint by completing and submitting the agency’s Title VI Complaint Form. 

 

  1. Formal complaints must be filed within 180 calendar days of the last date of the alleged act of discrimination or the date when the alleged discrimination became known to the complainant(s), or where there has been a continuing course of conduct, the date on which the conduct was discontinued or the latest instance of the conduct. 

 

  1. Complaints must be in writing and signed by the complainant(s) and must include the complainant(s) name, address and phone number.  The ADA/Title VI contact person will assist the complainant with documenting the issues if necessary.

 

  1. Allegations received by fax or e-mail will be acknowledged and processed, once the identity of the complainant(s) and the intent to proceed with the complaint have been established.  For this, the complainant is required to mail a signed, original copy of the fax or email transmittal for the complaint to be processed.

 

  1. Allegations received by telephone will be reduced to writing and provided to the complainant for confirmation or revision before processing.  A complaint form will be forwarded to the complainant for him/her to complete, sign and return for processing.

 

  1. Once submitted Jo Daviess County Transit, Operated by The Workshop will review the complaint form to determine jurisdiction. All complaints will receive an acknowledgement letter informing her/him whether the complaint will be investigated by the Jo Daviess County Transit, Operated by The Workshop or submitted to the State or Federal authority for guidance

 

  1. Jo Daviess County Transit, Operated by The Workshop will notify the IDOT Civil Rights Office of ALL Discrimination complaints within 72 hours via telephone at (217) 782-2762; or email at DOT.Complaint@illinois.gov

 

  1. Jo Daviess County Transit, Operated by The Workshop has 45 business days to investigate the complaint. If more information is needed to resolve the case, the Authority may contact the complainant. The complainant has 45 business days from the date of the letter to send 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 45 business days, the Authority can administratively close the case. A case can be administratively closed also if the complainant no longer wishes to pursue their case. 

 

  1. After the investigator reviews the complaint, she/he will issue one of two letters to the complainant: a closure letter or a letter of finding (LOF). A closure letter summarizes the allegations and states that there was not a Discrimination violation and that the case will be closed. An LOF summarizes the allegations and the interviews regarding the alleged incident, and explains whether any disciplinary action, additional training of the staff member or other action will occur. 

 

  1.  A copy of either the closure letter or LOF must be also be submitted to IDOT within 72 hours of that decision. Letters may be submitted by hardcopy or email.  

 

  1.  A complainant dissatisfied with Jo Daviess County Transit, Operated by The Workshop decision may file a complaint with the Illinois Department of Transportation (IDOT) or the Federal Transit Administration (FTA) offices of Civil Rights:  IDOT: ATTN ADA/Title VI Program Coordinator 69 W. Washington Street Room 2100 Chicago, IL 60602 FTA: Attention Title VI Program Coordinator, East Building, 5th Floor-TCR 1200 New Jersey Ave., SE Washington DC 20590 

 

  1.  A copy of these procedures can be found online at: www.jodaviesstransit.com.

 

If information is needed in another language, contact TYPE ALTERNATE LANGUAGE PHONE NUMBER HERE.  *Para información en Español llame: Kathy Gable, 815-777-8088 



 

Discrimination ADA/Title VI Complaint Form

Section I: 

Name: 

Address: 

Telephone (Home):

Telephone (Work):

Electronic Mail Address:

Accessible Format Requirements?

☐ Large Print

☐ Audio Tape

☐ TDD

☐ Other

Section II: 

Are you filing this complaint on your own behalf?

☐ Yes*

☐ No

*If you answered “yes” to this question, go to Section III.

If not, please supply the name and relationship of the person for whom you are complaining. 

 

Please explain why you have filed for a third party: 

Please confirm that you have obtained the permission of the aggrieved party if you are filing on behalf of a third party. 

☐ Yes

☐ No

Section III:

I believe the discrimination I experienced was based on (check all that apply):

 

☐ Race   ☐ Color ☐ National Origin                   ☐ Disability 

 

Date of Alleged Discrimination (Month, Day, Year): 

 

Explain as clearly as possible what happened and why you believe you were discriminated against. Describe all persons who were involved. Include the name and contact information of the person(s) who discriminated against you (if known) as well as names and contact information of any witnesses. If more space is needed, please use the back of this form.

 




 

Section VI:

Have you previously filed a Discrimination Complaint with this agency?

☐ Yes

☐ No

If yes, please provide any reference information regarding your previous complaint. 

 

Section V:

Have you filed this complaint with any other Federal, State, or local agency, or with any Federal or State court?

☐ Yes ☐ No

If yes, check all that apply:

☐ Federal Agency: 

☐ Federal Court:   ☐ State Agency: 

☐ State Court: ☐ Local Agency: 

Please provide information about a contact person at the agency/court where the complaint was filed.

Name:

Title:

Agency:

Address:

Telephone:

Section VI:

Name of agency complaint is against:

Name of person complaint is against:

Title:

Location:

Telephone Number (if available):

You may attach any written materials or other information that you think is relevant to your complaint.  Your signature and date are required below:

 

Signature Date

Please submit this form in person at the address below, or mail this form to:

 

Jo Daviess County Transit, Operated by The Workshop

Jo Daviess County Transit director 

710 S. WEST STREET, GALENA, IL 61036

815-777-8088

jodaviesstransit@yahoo.com

 

A copy of this form can be found online at www.jodaviesstransit.com

Discrimination ADA/Title VI Investigations, Complaints, and Lawsuits

 

If no investigations, lawsuits, or complaints were filed select the option below.

 

☒ Jo Daviess County Transit, Operated by The Workshop has not had any ADA nor Title VI Discrimination complaints, investigations, or lawsuits in 2020.

Complainant

Date (Month, Day, Year)

Basis of Complaint (Race, Color, National Origin or Disability)

Summary of Allegation

Status

Action(s) Taken

Final Findings?

Investigations






 

1)






 

2)






 

Lawsuits






 

1)






 

2)






 

Complaints






 

1)






 

2)






 

 

Public Participation Plan

Jo Daviess County Transit, Operated by The Workshop, is engaging the public in its planning and decision-making processes, as well as its marketing and outreach activities.  The public will be invited to participate in the process whether through public meetings or surveys.  

 

As an agency receiving federal financial assistance, Jo Daviess County Transit, Operated by The Workshop made the following community outreach efforts and activities to engage minority and Limited English Proficient populations since the last Title VI Plan submittal to IDOT CRO. 

 

☒ Expanded the distribution of agency brochures 

☒ Advertised public announcements through newspapers, fliers, or radio

☒ Posted the Nondiscrimination Public Notices to the following locations:

☒ Within transportation vehicles

☒ Lobby of agency

☒ Partnered with other local agencies to advertise services provided

 

☒ Added public interactive content to the agency’s webpage for the public e.g. social media, to communicate schedule changes or activities (Please provide a web link here)

☒ Hosted an information booth at a community event (Please insert the date of the event below) 


 

☒ Updated agency documents/publications to make them more user-friendly e.g. comment forms or agency brochures







 

Jo Daviess County Transit, Operated by The Workshop will make the following community outreach efforts for the upcoming year: 

 

☒ Expand the distribution of agency brochures 

☒ Advertise public announcements through newspapers, fliers, or radio 

☒ Post the Nondiscrimination Public Notices to the following locations:

☒ Pick up and drop off stations

☒ Partner with other local agencies to advertise services provided. 

☒ Host public information meetings and or hearings.

☒ Host an information booth at a community event 

☒ Update agency documents/publications to make them more user-friendly e.g. comment forms or agency brochures.   



 

 

Limited English Proficiency Plan

 

Jo Daviess County Transit, Operated by The Workshop has developed the following Limited English Proficiency Plan (LEP) to help identify reasonable steps to provide language assistance for LEP persons seeking meaningful access to Jo Daviess County Transit, Operated by The Workshop services as required by Executive Order 13166.  A Limited English Proficiency person is one who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English. 

 

This plan details procedures on how to identify a person who may need language assistance, the ways in which assistance may be provided, training to staff, notification to LEP persons that assistance is available, and information for future plan updates.  In developing the plan while determining the Jo Daviess County Transit, Operated by The Workshop’s extent of obligation to provide LEP services, the Jo Daviess County Transit, Operated by The Workshop undertook a U.S. Department of Transportation four-factor LEP analysis which considers the following:

 

  1. The number or proportion of LEP persons eligible in the Jo Daviess County Transit, Operated by The Workshop service area who may be served or likely to encounter by Jo Daviess County Transit, Operated by The Workshop program, activities, or services; 


 

U.S. Census Bureau

https://www.census.gov/quickfacts/fact/table/jodaviesscountyillinois/PST045219

QuickFacts 

Jo Daviess County, Illinois 

Population estimates, July 1, 2019, (V2019) 21,235  

PEOPLE 

Population 

Population estimates, July 1, 2019, (V2019) 21,235 Population estimates base, April 1, 2010, (V2019) 22,681 Population, percent change - April 1, 2010 (estimates base) to July 1, 2019, (V2019) -6.4% Population, Census, April 1, 2010 22,678 

Age and Sex 

Persons under 5 years, percent 4.3%  

Persons under 18 years, percent 18.7%  

Persons 65 years and over, percent 28.8%  

Female persons, percent 49.9%  

Race and Hispanic Origin 

White alone, percent 97.3%  

Black or African American alone, percent (a) 0.8%  

American Indian and Alaska Native alone, percent (a) 0.3%  

Asian alone, percent (a) 0.5%  

Native Hawaiian and Other Pacific Islander alone, percent (a) 0.1%  

Two or More Races, percent 1.1%  

Hispanic or Latino, percent (b) 3.2%  

White alone, not Hispanic or Latino, percent 94.4%  

Population Characteristics 

Veterans, 2015-2019 1,687 Foreign born persons, percent, 2015-2019 2.3% Housing 

Housing units, July 1, 2019, (V2019) 13,739 Owner-occupied housing unit rate, 2015-2019 78.4% Median value of owner-occupied housing units, 2015-2019 $149,100 Median selected monthly owner costs -with a mortgage, 2015-2019 $1,259 Median selected monthly owner costs -without a mortgage, 2015-2019 $544 Median gross rent, 2015-2019 $669 Building permits, 2019 19 Families & Living Arrangements 

Households, 2015-2019 9,970 Persons per household, 2015-2019 2.15 Living in same house 1 year ago, percent of persons age 1 year+, 2015-2019 89.0% Language other than English spoken at home, percent of persons age 5 years+, 2015-2019 3.3% Computer and Internet Use 

Households with a computer, percent, 2015-2019 87.8% Households with a broadband Internet subscription, percent, 2015-2019 80.2% 

Education 

High school graduate or higher, percent of persons age 25 years+, 2015-2019 92.3% Bachelor's degree or higher, percent of persons age 25 years+, 2015-2019 25.0% Health 

With a disability, under age 65 years, percent, 2015-2019 8.2% Persons without health insurance, under age 65 years, percent 6.6% 

Economy 

In civilian labor force, total, percent of population age 16 years+, 2015-2019 61.7% In civilian labor force, female, percent of population age 16 years+, 2015-2019 56.9% Total accommodation and food services sales, 2012 ($1,000) (c) 73,645 

Total health care and social assistance receipts/revenue, 2012 ($1,000) (c) 43,074 480,192 

Total manufacturers shipments, 2012 ($1,000) (c) 

Total merchant wholesaler sales, 2012 ($1,000) (c) 94,808 Total retail sales, 2012 ($1,000) (c) 293,688 Total retail sales per capita, 2012 (c) $13,024 Transportation 

Mean travel time to work (minutes), workers age 16 years+, 2015-2019 21.3 Income & Poverty 

Median household income (in 2019 dollars), 2015-2019 $57,946 Per capita income in past 12 months (in 2019 dollars), 2015-2019 $34,437 Persons in poverty, percent 9.3% 

Businesses 

Total employer establishments, 2018 706 Total employment, 2018 6,147 Total annual payroll, 2018 ($1,000) 220,128 Total employment, percent change, 2017-2018 -4.3% 

Total nonemployer establishments, 2018 1,920 All firms, 2012 2,234 Men-owned firms, 2012 1,226 Women-owned firms, 2012 601 Minority-owned firms, 2012 33 Nonminority-owned firms, 2012 2,141 Veteran-owned firms, 2012 138 Nonveteran-owned firms, 2012 1,819  

Geography 

Population per square mile, 2010 37.7 Land area in square miles, 2010 601.09 FIPS 


 

  1. The frequency with which LEP individuals come in contact with an Jo Daviess County Transit, Operated by The Workshop services; 

 

Jo Daviess County Transit, Operated by The Workshop’s staff reviewed the frequency with which office staff, dispatchers and drivers have, or could have, contact with LEP persons for 2020 . Jo Daviess County Transit, Operated by The Workshop averages 2 contacts per Month.


 

  1. The nature and importance of the program, activities or services provided by the Jo Daviess County Transit, Operated by The Workshop to the LEP population.


 

  1. The resources available to Jo Daviess County Transit, Operated by The Workshop and overall costs to provide LEP assistance.  A brief description of these considerations is provided in the following section.


 

Jo Daviess County Transit, Operated by The Workshop provides a statement in Spanish and will for additional languages specific to the LEP community make up that will be included in all public outreach notices.  Every effort will be made to provide vital information to LEP individuals in the language requested. 

 

Safe Harbor Provision for written translations

 

Jo Daviess County Transit, Operated by The Workshop complies with the Safe Harbor Provision, as evidenced by the number of documents available in the Spanish language. With respect to Title VI information, the following shall be made available in Spanish:

 

  1. Non-Discrimination Notice

  2. Discrimination Complaint Procedures

  3. Discrimination Complaint Form


 

In addition, we will conduct our marketing (including using translated materials) in a manner that reaches each LEP group. Vital documents include the following: 

 

  1. Notices of free language assistance for persons with LEP

  2. Notice of Non‐Discrimination and Reasonable Accommodation

  3. Outreach Materials

  4. Bus Schedules

  5. Route Changes

  6. Public Hearing



 

1) Jo Daviess County Transit, Operated by The Workshop provides language assistance services through the below methods:

 

2) Jo Daviess County Transit, Operated by The Workshop has a process to ensure the competency of interpreters and translation service through the following methods:

 

Jo Daviess County Transit, Operated by The Workshop will ask the interpreter or translator to demonstrate that he or she can communicate or translate information accurately in both English and the other language. Jo Daviess County Transit, Operated by The Workshop will train the interpreter or translator in specialized terms and concepts associated with the agency’s policies and activities. Jo Daviess County Transit, Operated by The Workshop will instruct the interpreter or translator that he or she should not deviate into a role as counselor, legal advisor, or any other role aside from interpreting or translator. Jo Daviess County Transit, Operated by The Workshop will ask the interpreter or translator to attest that he or she does not have a conflict of interest on the issues that they would be providing interpretation services.

 

3) Jo Daviess County Transit, Operated by The Workshop provides notice to LEP persons about the availability of language assistance through the following methods: 

 

4) Jo Daviess County Transit, Operated by The Workshop monitors, evaluates and updates the LEP plan through the following process:

 

Jo Daviess County Transit, Operated by The Workshop will monitor the LEP plan by conducting an annual Four-Factor analysis, establishing a process to obtain feedback from internal staff and members of the public and conducting internal evaluations to determine whether the language assistance measures are working for staff. Jo Daviess County Transit, Operated by The Workshop will make changes to the language assistance plan based on feedback received. Jo Daviess County Transit, Operated by The Workshop may take into account the cost of proposed changes and the resources available to them. Depending on the evaluation, Jo Daviess County Transit, Operated by The Workshop may choose to disseminate more widely those language assistance measures that are particularly effective or modify or eliminate those measures that have not been effective. Jo Daviess County Transit, Operated by The Workshop will consider new language assistance needs when expanding transit service into areas with high concentrations of LEP persons will consider modifying their implementation plan to provide language assistance measures to areas not previously served by the agency.

 

5) Jo Daviess County Transit, Operated by The Workshop trains employees to know their obligations to provide meaningful access to information and services for LEP persons and all employees in public contact positions will be properly trained to work effectively with in-person and telephone interpreters. Jo Daviess County Transit, Operated by The Workshop will implement processes for training of staff through the following procedures:

 

Jo Daviess County Transit, Operated by The Workshop will identify staff that are likely to come into contact with LEP persons as well as management staff that have frequent contact with LEP persons in order to target training to the appropriate staff. Jo Daviess County Transit, Operated by The Workshop will identify existing staff training opportunities, as it may be cost-effective to integrate training on their responsibilities to persons with limited English proficiency into agency training that occurs on an ongoing basis. Jo Daviess County Transit, Operated by The Workshop will include this training as part of the orientation for new employees. Existing employees, especially managers and those who work with the public may periodically take part in re-training or new training sessions to keep up to date on their responsibilities to LEP persons. Jo Daviess County Transit, Operated by The Workshop will implement LEP training to be provided for agency staff.  Jo Daviess County Transit, Operated by The Workshop staff training for LEP to include:

 

  • A summary of the Jo Daviess County Transit, Operated by The Workshop responsibilities under the DOT LEP Guidance;  

  • A summary of the Jo Daviess County Transit, Operated by The Workshop language assistance plan;  

  • A summary of the number and proportion of LEP persons in the Jo Daviess County Transit, Operated by The Workshop service area, the frequency of contact between the LEP population and the agency’s programs and activities, and the importance of the programs and activities to the population;  

  • A description of the type of language assistance that the agency is currently providing and instructions on how agency staff can access these products and services; and  

  • A description of the Jo Daviess County Transit, Operated by The Workshop cultural sensitivity policies and practices.




 

*PROVIDE SAMPLE DOCUMENTS YOUR AGENCY PROVIDES FOR LEP INDIVIDUALS


 

Jo Daviess County Transit, Operated by The Workshop (y sus subcontratistas, si cualquiera) asegura cumplir con el Título VI de la Ley de los Derechos Civiles de 1964, Sección 504 de la Ley de Rehabilitación de 1973 y La Ley de ciudadanos americanos con Discapacidades de 1990 (ADA).   El nivel y la calidad de servicios de transporte serán proveídos sin consideración a su raza, color, país de origen, o discapacidad. 

 

Para obtener más información sobre el programa de Derechos Civiles de Jo Daviess County Transit, Operated by The Workshop, y los procedimientos para presentar una queja, contacte Jo Daviess County Transit director 815-777-8088, (TTY 800-526-0857); o visite nuestra oficina administrativa en 710 S. WEST STREET, GALENA, IL 61036.  Para obtener más información, visite www.jodaviesstransit.com

 

Una queja puede ser presentada con la oficina de Derechos Civiles del Departamento de Transporte de Illinois (IDOT).  Atención: Title VI Program Manager, 69 W. Washington Street Chicago, IL 60602 o con la Administración Federal de Transporte (FTA).  Ate45nción: Title VI Coordinator, 1200 New Jersey Ave., SE Washington DC 2059

Non-elected Committees Membership Table

Subrecipients who select the membership of transit-related, non-elected planning boards, advisory councils, or committees must provide a table depicting the membership of those organizations broken down by race. Subrecipients also must include a description of the efforts made to encourage participation of minorities on these boards, councils, and committees.

 

☒ Jo Daviess County Transit, Operated by The Workshop does not select the membership of any transit-related committees, planning boards, or advisory councils.


 

*Table Depicting Membership of Committees, Councils, Broken Down by Race

 

Monitoring for Subrecipient Title VI Compliance

Describe how you monitor your subrecipients. This can be through site visits, submissions of Title VI Plans annually, or training and surveys.

 

☒ Jo Daviess County Transit, Operated by The Workshop does not monitor subrecipients for Title VI compliance. 

 

*Primary recipients must monitor subrecipients.

  • Non-compliant subrecipient means primary recipient is also non-compliant.

*Primary recipients shall:

  • Document process for ensuring all subrecipients are complying with general reporting requirements of FTA Circular 4702.1B and other requirements that apply to the subrecipient.

  • Collect, store and review subrecipients’ Title VI Programs.

  • At FTA’s request, the primary recipient shall request that subrecipients who provide transportation services verify that their level and quality of service is equitably provided.

Title VI Equity Analysis

A subrecipient planning to acquire land to construct certain types of facilities must not discriminate on the basis of race, color, or national origin, against persons who may, as a result of the construction, be displaced from their homes or businesses. “Facilities” in this context does not include transit stations or bus shelters, but instead refers to storage facilities, maintenance facilities, and operation centers.

 

There are many steps involved in the planning process prior to the actual construction of a facility. It is during these planning phases that attention needs to be paid to equity and non-discrimination through equity analysis. The Title VI Equity Analysis must be done before the selection of the preferred site.

 

Note: Even if facility construction is financed with non-FTA funds, if the subrecipient organization receives any FTA dollars, it must comply with this requirement.


 

☒ Jo Daviess County Transit, Operated by The Workshop has no current or anticipated plans to develop new transit facilities covered by these requirements 


 

  1. Introduction 

 

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. Per 49 CFR 21.9(b)(3), recipients may not select the site or location of facilities with the purpose or effect of excluding persons from, denying the benefits of, or subjecting them to discrimination on the basis of race, color, or national origin.  Additionally, the location of projects requiring land acquisition and the displacement of persons from their residences and business may not be determined on the basis of race, color, or national origin.  

This document is an analysis of Jo Daviess County Transit, Operated by The Workshop’s planned TYPE PROPOSED MONTH/YEAR OF AGENCY COMPLETION TYPE AGENCY HERE (Facility Construction Only)

 

  1. Background

 

Describe the Agency (why it was proposed, the projected benefits of the project, etc.)

 

  1. Analysis 

 

For facilities covered by this provision, recipients are required to:

 

  1. Complete a Title VI equity analysis during the planning state with regard to where an agency is located to ensure the location is selected without regard to race, color, or national origin, and engage in outreach to persons potentially impacted by siting of facilities.  The Title VI equity analysis must compare the equity impacts of various siting alternatives, and the analysis must occur before the selection of the preferred site.

 

  1. Give attention to other facilities with similar impacts in the area to determine if any cumulative adverse impacts might result.  Analysis should be done at the Census tract or block group level where appropriate to ensure proper analysis of localized impacts.

  2. Provide substantial legitimate justification for locating an agency in a location that will result in a disparate impact on the basis of race, color, or national origin, and show that there are no alternative locations that would have a less disparate impact on the basis of race, color, or national origin.  In order to show that both tests have been met, the recipient must consider and analyze alternatives to determine whether those alternatives would have less of a disparate impact on the basis of race, color, or national origin, and then implement the least discriminatory alternative.

Fixed Route Transit Provider Analysis



 

☒  Jo Daviess County Transit, Operated by The Workshop is not a Fixed Route Transit Provider




 

Board Approval for the Title VI Plan

wksp board approval  Title IV.png
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