Title VI Policy

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.

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.

The United States is home to millions of national origin minority individuals with 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.  

ANALYSIS OF FACTORS

No. 1:  The number or proportion of LEP persons in the service area.
According to the 2019 American Community Survey 5-Year Estimates, the total population 5 years and over for Chelan County is 71,571, and the corresponding population in Douglas County is 39,272. This creates a combined population 5 years and over of 110,853 in the two counties. English is spoken by 73.9% (52,880) of Chelan County and 70.8% (27,817) of Douglas County residents. 
 
Spanish is the dominant language spoken by non-English speakers in the region. Spanish speaking in the household represents 24.4% (17,470) of non-English speaking Chelan County and 27.2% (10,667) of non-English speaking Douglas County residents. In total, 10.7% and 12.6% of the overall population in Chelan and Douglas County, respectively, speak English less than “very well” and speak Spanish as their primary language.
 
Other languages spoken by residents who speak English less than “very well” in Chelan County include Indo-European languages (1.2% or 885 people), Asian and Pacific Island languages (0.3% or 241 people), and all other languages (0.1% or 95 people). Likewise in Douglas County, other languages spoken by residents who speak English less than “very well” include Indo-European languages (1.2% or 487 people), Asian and Pacific Island languages (0.6% or 243 people), and all other languages (0.1% or 58 people).

No. 2.  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, and demand response services. Guest Services Representatives speak Spanish and translate in person or over the phone a total of approximately 10 to 12 times per day. 

No. 3:  The nature and importance of service provided by Link Transit.  
Link Transit provides important transit services to the public through its fixed route and paratransit programs as well as bilingual (English/Spanish) Mobility Management and Travel Training services.

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 are fluent in these languages. They serve as interpreters as needed on those occasions when a person with LEP 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. Language Line is a contracted service that connects Link Transit representatives to professional interpreters in more than 240 languages via telephone. Additionally, Link Transit has an outreach program where Spanish-speaking customers are taught how to ride the bus through training and one-on-one assistance.   

• Link Transit provides most publications, including schedules and posted Rider Alerts, in both English and Spanish.
• Special notices of public meetings and other events are made available in Spanish. 
• Link Transit budgets yearly for Language Line.

Link Transit identifies LEP persons in the service area by ridership, on-board surveys, and using planning and geographic analysis software to review Census data trends. Using this information, Link Transit implements language services according to the published plan. Link Transit intends to conduct an on-board survey during the timeframe of this Title VI plan in a continuing effort to improve our service to LEP persons.

When possible, Link Transit seeks to hire guest services representatives that are bilingual (Spanish/English). Our Executive Assistant/Clerk of the Board is bilingual and is made available to assist with Spanish-speaking customers.  Approximately 20-25% of Link Transit’s coach operators are also bilingual in English and Spanish. Operation Dispatchers and Guest Services representatives are trained to use Language Line.

Link Transit publishes most of its on-board and street-side rider information in English and Spanish. The annual Ride Guide is a free booklet available on all Link Transit buses and at various other locations (Columbia Station, public libraries, hospitals, and some larger employers) that explains all aspects of Link’s service. The entire Ride Guide is printed in English and Spanish. All information posted at bus stops, including bus schedules and route detours/changes, are provided in English and Spanish. Additional tools to assist riders find buses in real-time are also posted at sheltered bus stops in both English and Spanish.

Link Transit’s Title VI policy and a Complaint Form are available on our website in both English and Spanish. All printed maps and schedules contain Title VI language in both English and Spanish, and Link posts English and Spanish flyers on the bus as the information changes. Bilingual employees also assist our Marketing Coordinator when visiting employers and businesses in the community to educate individuals about the services we provide. Link also has the assistance from Spanish-speaking employees when promoting increasing bus service or frequency to large employers with a LEP/Spanish-speaking demographic. Continuing efforts have been made to educate these employers that Link’s service is now zero fare through at least June 30, 2022.

In order to comply with 49 CFR 21.9(d), Link Transit and its sub-recipients 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. At this time Link Transit has no sub- recipients.

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

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) and 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 Human Resources staff at our Operations Base.

3. If information is needed in another language, contact the Title VI Coordinator at 509-664-7668.

Community outreach is a requirement of Title VI. Recipients and sub-recipients 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. Link Transit has developed a comprehensive Public Participation Plan (PPP) which outlines the goals and objectives for public participation (see Attachment C). From 2018-2021, the public was invited to participate in these activities (see Attachment D):

Transit Development Plan (TDP). The TDP is a requirement of the Washington State Legislature. The plan is prepared by independent transit properties and submitted annually to the Washington State Department of Transportation (WSDOT). A summary document with information such as the size of the fleet, costs, revenues, service revenue hours, revenue miles, expenses, and capital expenditures is provided for public review. Public hearings are held to obtain comments on the TDP.

Transit Improvement Plan (TIP).  The Transit Improvement Plan is prepared by the cities and counties. The TIP is a planning document that addresses capital projects and improvement projects in cities and counties. All TIPs from local jurisdictions (counties and cities) as well as the Link’s TDP are collected into a Regional TIP (RTIP) by the Chelan Douglas Transportation Council, which is required by the federal government. The TIP is only for federally-funded capital projects and represents the capital section of the TDP; federally-funded projects must be listed in the RTIP prior to such funding being obligated. Public hearings are held to obtain comments from the public on the RTIP.

Board Meetings.  The Board of Directors holds monthly meetings, which are noticed and opened to the public.

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

Major Service Change. The public was included in engagement conducted as part of the Vision 2020 process (described in greater detail in the “General Awareness and Public Outreach” section below) regarding local service needs and potential service changes. At each of these meetings, Spanish-speaking employees were in attendance to assist individuals who do not speak English.

Fare Increase.  Public hearings are set when a fare increase is proposed by Link Transit, and Spanish-speaking employees are in attendance to assist individuals who do not speak English. Beginning in early 2020, Link Transit implemented a zero fare policy on all of its services in response to the COVID-19 pandemic. Link Transit extended this policy as part of a one-year pilot program from July 1, 2021 through June 30, 2022 in an effort to provide equitable service for all citizens within our PTBA. All rides are free for all members of the public during this pilot program, which will be evaluated for permanent implementation in 2022.

Travel Training Class. Link Transit has developed a travel training program to reach out to community groups (senior centers, senior facilities, and the disabled community) to conduct travel training classes. Since 2011, we have been able to expand travel training to Spanish-speaking guests by cross training a Spanish-speaking Guest Services Representative to assist with the program. Travel training classes are ongoing.

Customer Complaint Process. Citizens may call Link’s Guest Services Department at 509-662-1155 to lodge a complaint or comment. All complaints/comments are input into a database and distributed to the relevant manager who researches the complaint and responds back to the citizen. 

General Awareness and Public Outreach. Link Transit engaged in a multi-part public survey beginning in 2016 for community input regarding future planning and service to potentially expand Link’s level of service. Link engaged in an extensive community outreach effort that became known as Vision 2020 to understand the needs of the public and willingness to be taxed to meet those needs. Through two separate survey efforts, Link Transit received more than 4,000 responses and hundreds of written comments. These surveys were conducted in person on Link buses and at Link facilities, were made available in English/Spanish, advertised in local news media and social media platforms, mailed discrete survey response documents to each household in Link’s public transportation benefit area, and developed a website for response.

Following the Vision 2020 outreach process, a proposal to fund service expansion by increasing sales tax by 0.2% was placed on the ballot. In August 2019, voters approved the sales tax increase initiative in an effort to expand and improve Link’s service in the upcoming years. Link Transit subsequently contracted an outside consulting firm to conduct comprehensive service analysis to review and evaluate the effectiveness and efficiency of Link Transit’s fixed-route service and to develop alternative future service plans. The study was conducted from Spring 2020 through Summer 2021. A variety of outreach methods were implemented to encourage public engagement during the process, including websites, newspaper ads, virtual open house, residential mailers, posters and flyers in buses. All of these engagement tools were provided in both Spanish and English.

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.