Title VI Plan and Complaint Procedure
Title VI Plan 2024- 2026
I. Introduction to Title VI
Title VI of the Civil Rights Act of 1964 is the main legal authority for the Office of Equal Rights External Civil Rights Division nondiscrimination programs. Title VI prohibits discrimination on the basis of race, color, or national origin in programs or activities receiving federal financial assistance. Once an agency accepts federal funds, all of its programs and activities are covered, regardless of their funding source. Related statutes and Presidential Executive Orders under the umbrella of Title VI address Environmental Justice (EJ) in minority and low-income populations and services to individuals with Limited English Proficiency (LEP), women, and people with disabilities.
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, national origin, or LEP status as protected by Title VI of the Civil Rights act.
II. Title VI Mission
Link Transit’s Title VI Program’s primary goal is to ensure all management, staff, contractors, local agencies, and service beneficiaries are aware of the provisions of Title VI and the responsibilities associated with Title VI of the Civil Rights Act of 1964.
The Title VI Program is responsible for providing leadership, direction, and policy to ensure compliance with Title VI, EJ, and LEP principles. The program also aims to ensure that social impacts to communities and people are recognized and considered throughout the transportation planning and decision-making process.
III. What is Title VI
Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, or national origin in programs or activities receiving federal financial assistance. Related statutes and Presidential Executive Orders under the umbrella of Title VI also address protections for EJ, LEP individuals, women, and people with disabilities. When an agency accepts federal funds, all of its programs and activities are covered by Title VI, regardless of their funding source.
IV. What does this mean for Link Transit?
Link Transit cannot, on the basis of race, color, national origin, or sex, either directly or through contractual means:
- Deny program services, aids, or benefits;
- Provide a different service, aid, or benefit, or provide them in a manner different than what is provided to others;
- Segregate or separately treat individuals in any manner related to the receipt of any service, aid, or benefit.
This plan documents Link Transit’s efforts to comply with these requirements.
¿Qué significa esto para Link Transit?
Link Transit no puede, por motivos de raza, color, origen nacional o sexo, ya sea directamente o a través de medios contractuales:
- Negar servicios, ayudas o beneficios del programa;
- Proporcionar un servicio, ayuda o beneficio diferente, o proporcionarlos de manera diferente a como se proporciona a otros;
- Segregar o tratar por separado a las personas en cualquier manera relacionada con la recepción de cualquier servicio, ayuda o beneficio.
Este plan documenta los esfuerzos de Link Transit para cumplir con estos requisitos.
To obtain additional information about your rights under Title VI or to file a complaint, contact:
Link Transit
Title VI Coordinator
300 S. Columbia St
Wenatchee, WA 98801
By phone: 509-662-1155
By email: TitleVI@linktransit.com
How to file a Title VI Complaint
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 of the Civil Rights Act. If you believe you have been subjected to discrimination under Title VI, you have the right to file a complaint. The following procedures outline how to file a Title VI complaint:
- Complaint Filing Timeline: You may file a signed, written complaint no later than 180 days from the date of the alleged discrimination.
- Required Information: The written complaint must include the following information:
- Your name, mailing address, and preferred contact information (e.g., phone number, email address).
- A detailed description of the incident, including how, when, where, and why you believe you were discriminated against. Please provide any specific details such as location, names, and contact information of witnesses.
- Any other relevant information that will assist in the investigation of the complaint.
- Complaint Form: For your convenience, a Title VI Complaint Form is available below, on our website, and at our Columbia Station location and at our Operations and Maintenance Facility location. However, use of the form is not required as long as all required information as described above is included.
- Submission: Your complaint may be submitted to Link Transit by mail, phone, or email.
Note: It is recommended to send complaints via certified mail or another trackable method to ensure receipt.
What happens to my complaint after it is submitted to Link Transit?
- Complaint Acknowledgment: Upon receipt of your complaint, Link Transit will acknowledge it in writing within 10 working days excluding major holidays. We will review the complaint to determine if it falls under Title VI jurisdiction (i.e., allegations of discrimination based on race, color, or national origin).
- Assistance: Link Transit will provide reasonable assistance to any individual needing help in filing a complaint, including those with disabilities or limited English proficiency (LEP).
- Investigation Process: If the complaint is accepted for investigation, Link Transit will initiate a formal investigation process. In some cases, additional information may be needed from the complainant. Failure to provide the requested information may result in administrative closure of the complaint.
- Resolution: Once sufficient information is gathered, Link Transit will:
- Prepare a written response.
- Share the findings with the complainant.
- Review the response internally, including legal review if necessary.
- Administrative Closure: If the investigation determines that there was no violation, or if the complaint lacks sufficient evidence, the complaint may be administratively closed. In such instances, Link Transit will inform the complainant of the closure and the reasons for it.
How will I be notified of the outcome of my complaint?
- Final Response: Link Transit will send the complainant a written final response. The response will include the outcome of the investigation and any corrective actions, if applicable.
- Appeal Process: If you disagree with the final decision, you have the right to:
- Appeal the decision within 7 working days from the date of receipt of the final written decision.
- File a complaint with external agencies, including:
- U.S. Department of Transportation (USDOT)
- Federal Transit Administration (FTA) Office of Civil Rights
- Record Keeping: Link Transit will retain copies of all complaints, investigative reports, and written responses for a period of no less than three (3) years. Records of complaints will be reported to the FTA during the Title VI Program submission cycle, including the total number of complaints, how they were resolved, and any corrective actions taken.
LIMITED ENGLISH PROFICIENCY (LEP) PLAN
I. Overview
Link Transit is committed to overcoming language barriers by implementing consistent standards of language assistance across its service area, ensuring meaningful access for individuals with LEP. These individuals, whose primary language is not English, may have difficulty communicating effectively. Under Title VI of the Civil Rights Act of 1964, agencies receiving federal funding must take reasonable steps to ensure LEP persons have meaningful access to programs, services, and information.
II. Four-Factor Analysis
Factor 1: Number or Proportion of LEP Persons in the Service Area
Based on the 2022 American Community Survey (ACS) Five-Year Estimates, Chelan and Douglas Counties have significant populations of residents who do not speak English as their primary language and speak English “less than very well.” Spanish is the dominant language spoken by LEP individuals.
Language | Chelan County | Douglas County |
English Spoken at Home | 73.9% | 71.5% |
Language Other than English | 26.1% | 28.5% |
Spanish Speakers | 22.7% | 25.4% |
English Less Than “Very Well” | 10.1% | 12.2% |
Factor 2: Frequency of Contact with LEP Individuals
LEP individuals interact with Link Transit daily across various services, including bus services, paratransit, demand response services, and customer service interactions. Approximately 10-12 contacts are made daily with Spanish-speaking individuals via guest service representatives. Approximately 12% of our riders are LEP individuals according to our most recent on-board survey in 2023. Link Transit staff, including guest service representatives and operational staff, are trained to assist LEP individuals, with many staff members being bilingual.
Factor 3: Nature and Importance of the Service to LEP Persons
Link Transit provides essential public transportation services that are critical for LEP individuals to access employment, education, healthcare, and other necessary services. Link Transit offers both fixed-route and paratransit services as well as mileage reimbursement program and rideshare program. Translators for travel training are available to ensure LEP persons can access the full range of transit services.
Factor 4: Resources Available and Costs to Assure Meaningful Access
Link Transit provides the following resources to ensure LEP individuals have meaningful access:
- Bilingual Staff: As of this plan date, Link Transit employs bilingual (Spanish/English) guest service representatives, supervisors, and operators. Approximately 25-30% of coach operators are bilingual.
- Language Line Services: Link Transit subscribes and trains staff to utilize Language Line, which connects staff to interpreters in over 240 languages.
- Outreach Program: Spanish-speaking customers are provided with assistance on how to ride the bus, including one-on-one travel training with the use of an interpreter as needed
- Partnerships: Link Transit partners with local organizations like Community for the Advancement of Family Education (CAFÉ) to provide additional translation and interpretation services as needed.
III. Language Assistance Plan
- Publications: Essential materials such as schedules, Rider Alerts, and the annual Ride Guide are available in both English and Spanish. Public meeting notices and other key documents are translated into Spanish to ensure that LEP individuals are informed of important updates.
- Public Meetings: Upon request Link Transit provides Spanish-language translation services at public meetings and ensures that bilingual staff are available to assist LEP participants.
- On-Board and Street-Side Information: Transit schedules, stop information, and announcements on buses are available in English and Spanish to ensure LEP individuals can navigate the system effectively.
- Digital and Printed Media: Link Transit’s Title VI policy, complaint forms, and service-related information are provided on the website and in printed materials in both English and Spanish to meet the needs of LEP populations.
- Language Line Services: Link Transit’s partnership with Language Line Services enables real-time access to professional interpreters in over 240 languages. Link transit trains staff members in dispatch, operations, and customer service how to utilize this tool.
- Outreach and Education: Interpreters and bilingual employees help with outreach to large employers, educate LEP communities about transit services, and promote programs such as zero-fare services. Outreach efforts ensure that LEP individuals understand how to access Link Transit’s services.
VI. Implementation and Monitoring
- Ongoing Monitoring: Link Transit uses ridership data, onboard surveys, and Census data to regularly assess the needs of LEP individuals. Annual reviews of Language Line usage, community feedback, and service performance help identify any areas needing improvement.
- LEP Population Surveys: An on-board survey was conducted in 2023 in both English and Spanish to assess existing transit service needs, including for LEP populations. Link Transit will continue to conduct similar surveys approximately every five years or as needed to keep up-to-date with changing demographics.
- Hiring Practices: Link Transit prioritizes the hiring of bilingual staff, particularly for roles that interact with LEP individuals and the public.
- Budgeting for Language Services: Link Transit budgets annually to maintain and expand Language Line services, in addition to maintaining partnerships with organizations like CAFÉ for translation and interpretation support.
V. Compliance with 49 CFR 21.9(d)
Link Transit complies with 49 CFR 21.9(d) by providing beneficiaries with information about their rights under Title VI. This includes prominently posting the Title VI policy statement and complaint forms in both English and Spanish on the website, and administrative offices. LEP individuals are informed of their rights and the procedures for filing a complaint.
NOTIFYING BENEFICIARIES OF THEIR RIGHTS UNDER TITLE VI
NOTIFYING BENEFICIARIES OF THEIR RIGHTS UNDER TITLE VI
Link Transit does not discriminate on the basis of race, color, or national origin in accordance with Title VI of the Civil Rights Act of 1964. Any person who believes they have been discriminated against based on race, color, or national origin may file a Title VI complaint with Link Transit.
To file a complaint, contact:
Mail: | Link Transit Title VI Coordinator 300 South Columbia Street Wenatchee, WA 98801 | Email address: titlevi@linktransit.com Phone number: (509) 662-1155 |
Complaints must be filed within 180 days of the alleged discriminatory action. This Title VI Notice to the Public is posted on our website at linktransit.com and at Columbia Station (300 South Columbia Street, Wenatchee WA). A Title VI Complaint Form is available in this plan, on our website, at our Operations and Maintenance Facility (2700 Euclid Avenue, Wenatchee, WA), and at Columbia Station (300 South Columbia Street, Wenatchee, WA). Individuals who believe they have been discriminated against may request a complaint form from our Guest Services staff or Human Resources staff.
For more information about Link Transit’s Title VI obligations or to request information in another language, please contact the Title VI Coordinator at the above contact information.
NOTIFICACIÓN A LOS BENEFICIARIOS DE SUS DERECHOS BAJO EL TÍTULO VI
Link Transit no discrimina por motivos de raza, color u origen nacional de conformidad con el Título VI de la Ley de Derechos Civiles de 1964. Cualquier persona que crea que ha sido discriminada por motivos de raza, color u origen nacional puede presentar una queja conforme al Título VI ante Link Transit.
Para presentar una queja, comuníquese con
Dirección de envío | Link Transit Coordinador del Título VI 300 South Columbia Street Wenatchee, WA 98801 | Dirección de correo electrónico: titlevi@linktransit.com Número de teléfono: (509) 662-1155 |
Las quejas deben presentarse dentro de los 180 días posteriores a la presunta acción discriminatoria. Este Aviso al público del Título VI se publica en nuestro sitio web en linktransit.com y en la estación Columbia (300 South Columbia Street, Wenatchee WA). Hay un formulario de queja del Título VI disponible en este plan, en nuestro sitio web, en nuestras instalaciones de operaciones y mantenimiento (2700 Euclid Avenue, Wenatchee, WA) y en la estación Columbia (300 South Columbia Street, Wenatchee, WA). Las personas que crean que han sido discriminadas pueden solicitar un formulario de queja a nuestro personal de Servicios para huéspedes o al personal de Recursos humanos.
Para obtener más información sobre las obligaciones del Título VI de Link Transit o para solicitar información en otro idioma, comuníquese con el Coordinador del Título VI a la información de contacto indicada anteriormente.
El Título VI de la Ley de Derechos Civiles de 1964 exige que “Ninguna persona en los Estados Unidos, por motivos de raza, color o origen nacional, ser excluido de participar en, ser negado de los beneficios de, o ser sujeto a discriminación bajo cualquier programa o actividad que recibe asistencia financiera federal”. Si siente que ha sido discriminado en tránsito servicios, por favor proporcione la siguiente información para ayudarnos a procesar su queja y enviarla a la nombre listado abajo.
INCLUSIVE PUBLIC PARTICIPATION
I. Introduction
Link Transit is dedicated to ensuring that all residents, especially historically underserved populations, have meaningful access to public participation opportunities in transportation planning, in compliance with Title VI of the Civil Rights Act of 1964. This Public Participation Plan (PPP) outlines how Link Transit will engage the public. Link Transit’s outreach efforts seek to involve traditionally underrepresented groups, including minority, low-income, and LEP populations, as required by the Title VI of the Civil Rights Act.
II. Goals and Objectives
The primary goal of this PPP is to ensure that all citizens, including low-income, minority, and LEP populations, have the opportunity to contribute, have access to information about our programs, and participate in the development of plans and projects. To achieve this, the objectives are:
- Identify non-English languages and cultural barriers that impact public participation.
- Provide accessible and clear notifications of public meetings in English and Spanish to ensure broad outreach.
- Ensure meetings are held in accessible, welcoming locations that are transit-accessible, ADA-compliant, and located near communities with significant minority and LEP populations.
- Offer multiple channels for two-way communication with populations unlikely to attend meetings, such as online comment forms and virtual meetings.
- Use visual aids (charts, maps, photos) to enhance understanding of the material.
- Incorporate culturally relevant communication methods to engage diverse communities (e.g., partnerships with local community organizations).
- Encourage feedback via online surveys, phone, and in-person meetings.
- Evaluate the effectiveness of outreach efforts and adjust strategies as needed based on community feedback.
III. Public Participation Methods
Link Transit employs a variety of methods to engage the public, with special attention to minority, low-income, and LEP populations:
- Public Notices: Information about public hearings and meetings is sent to local entities such as newspapers, media outlets, community centers, libraries, churches, and posted on Link Transit’s social media, and website.
- Public Hearings: Held to discuss major service changes, fare increases, and planning documents such as the Transit Development Plan (TDP).
- Board Meetings: Monthly Board of Directors meetings are open to the public, with Spanish-speaking representatives available for assistance upon request. Meeting notices are made available in Spanish and posted at high-traffic public locations such as transit centers and libraries.
- Outreach to Minority and LEP Populations: Interpreters or Spanish-speaking staff assist with outreach, public meetings, and travel training programs to ensure engagement with the Spanish-speaking population, which comprises a significant portion of the service area. Link partners with local organizations to extend outreach to LEP communities.
- Bilingual Services: Essential documents, including service announcements, the Ride Guide, feedback form, printed materials, and the Title VI, are available in both English and Spanish. Additional languages may be accommodated based on community needs as identified in the four-factor LEP analysis. Language Line services are available for additional languages.
- Surveys: Link Transit conducts surveys (both online and in-person) in English and Spanish to gather community feedback on service changes and needs. Surveys are distributed at locations that are frequented by low-income and minority populations, such as grocery stores, health clinics, and schools.
- Travel Training: Link Transit offers travel training for all individuals and can provide training for Spanish-speaking residents with the services of an interpreter to ensure everyone understands how to use transit services effectively. Bilingual travel training materials are made available in Spanish and tailored to the needs of those over the age of 60 and LEP populations.
- Virtual Meetings and Online Tools: Link Transit provides virtual public meetings to engage a broader audience, particularly for individuals who may face barriers attending in-person events. Webinars and other online engagement tools are used to facilitate participation in service planning and decision-making processes.
VI. Stakeholders
- General Public: Riders, residents, and potential users of Link Transit services.
- Title VI Protected Populations: Minority groups, LEP individuals, low-income populations, and individuals with disabilities.
- Community Organizations: Local advocacy groups representing the interests of underserved communities.
- Government & Public Agencies: Local elected officials, social service agencies, and environmental justice organizations that have insight into the needs of underrepresented populations
V. Ongoing Outreach Efforts
Link Transit continues to employ a range of techniques to engage the public, including:
- Presentations to community organizations.
- Interviews with local media (English and Spanish with the service of an interpreter as needed).
- Distribution of public information through newsletters, social media, and press releases.
- Targeted outreach to low-income communities through social service agencies and community-based organizations.
- Use of social media platforms, including Facebook and Instagram, to engage the public in real-time discussions and to promote public meetings. All pictures and graphics with text are in English and in Spanish.
- Surveys distributed on buses and at transit facilities, available in both English and Spanish.
- Use of visual tools like charts, maps, and online platforms to make complex information more accessible.
VII. Monitoring and Evaluation
- Link Transit will monitor and evaluate the effectiveness of its public participation efforts through metrics such as attendance at public meetings, the number of comments received, and demographic data on survey respondents.
- An annual review of outreach efforts will be conducted to identify areas for improvement and ensure that strategies are effectively engaging historically underrepresented and overburdened populations.
VII. Conclusion
Link Transit is committed to ensuring all segments of the population have the opportunity to meaningfully participate. The PPP will be continuously reviewed and updated as necessary to ensure that outreach efforts meet the needs of our community, especially those traditionally underrepresented in public planning processes.