civil rights and public transportation presented for: ohio department of transportation september,...
TRANSCRIPT
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CIVIL RIGHTS AND PUBLIC
TRANSPORTATION
Presented for: Ohio Department of Transportation
September, 2008
Presented By: Robbie SarlesRLS & Associates, Inc.
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OBJECTIVES
Provide an overview of civil rights legislation Enable agencies to assess compliance Provide guidance on methods to eliminate or
prevent civil rights violations Procedures for resolving discrimination
complaints
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CIVIL RIGHTS RELATED REQUIREMENTS FOR TRANSIT
Title VI of the Civil Rights Act of 1964 Providing Language Access to Persons
with Limited English Proficiency (LEP) – Executive Order 13166
Environmental Justice – Executive Order 12898
Americans with Disabilities Act (ADA)
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TITLE VI
Applies to all FTA recipients and sub-recipients• “No person in the United States shall, on the
grounds of race, color, or national origin, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance.”
• 42 U.S.C., Section 2000d
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TITLE VI PROTECTS
Anyone intended to be the beneficiary of, applicant for, or participant in a Federally assisted program
Applies to all persons• All races• All shades of color• National Origin
Later statutes extended the scope of Title VI to include prohibitions against discrimination on the basis of income, age, sex, and disability
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DOT AND DOJ REGULATION
Prohibits disparate impact discrimination• Practice lacks a substantial legitimate justification• There are other comparable alternatives that
would result in less disparate impact• The justification is a pretext for discrimination
Intentional discrimination
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DOT TITLE VI REGULATIONS
Recipients may not:• Deny any protected individual service, financial
aid, or benefit under the program• Provide any service, financial aid, or benefit that
is different for protected individuals from that provided to others
• Subject a protected individual to segregation or separate treatment
• Restrict a protected individual in the employment of any advantage or privilege enjoyed by others
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DOT TITLE VI REGULATIONS (CONTINUED)
Recipients may not: (continued)• Treat protected individuals differently in terms of
whether they satisfy admission, eligibility, or membership requirements
• Deny a protected individual the opportunity to participate in the provision of services
• Deny a protected individual the opportunity to participate as a member of a planning or advisory body
• Use criteria or methods of administration that have the effect of subjecting individuals to discrimination
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DOT TITLE VI REGULATIONS (CONTINUED)
Recipients may not: (continued)• Make decisions in regard to facility location with
the purpose or effect of subjecting persons to discrimination
• Discriminate with regard to the routing, scheduling, or quality of transit service
• Use race, color, or national origin as a basis for determining frequency of service, age and quality of vehicles assigned to routes, quality of stations serving different routes, and location of routes
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DOT TITLE VI REGULATIONS (CONTINUED)
Recipients must:• Take affirmative action to assure non-
discrimination
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FTA GUIDANCE FOR COMPLIANCE
Title VI Program Guidelines to FTA Recipients• FTA Circular 4702.1
www.fta.dot.gov• Civil rights / accessibility
Annual Title VI Assurances• Annual certification and assurance submission
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EIGHT REQUIRED ACTIONS
1. Develop Title VI complaint procedures• Develop method for filing complaints• Develop method for investigating and tracking
complaints• See example
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EIGHT REQUIRED ACTIONS (CONTINUED)
2. Record Title VI investigations, complaints, and lawsuits• Maintain a list of active investigations conducted
by entities other than FTA, lawsuits or complaints alleging discriminationo Date filedo Summary of allegationo Current statuso Actions taken in response
• See example
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* ODOT should be notified immediately in the case of a lawsuit or complaint alleging discrimination
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EIGHT REQUIRED ACTIONS (CONTINUED)
3. Provide meaningful access to persons with Limited English Proficiency – benefits, services, information, and other important portions of their programs• Develop an LEP Plan or equivalent
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EIGHT REQUIRED ACTIONS (CONTINUED)
4. Notify beneficiaries of Title VI protections• Disseminate information to public
o Statement that agency operates programs without regard to race, color, national origin, sex, age, income, or disability (should be included in all printed materials regarding service)
o Procedures for requesting additional information on non-discrimination obligations
o Compliant procedures• Use variety of dissemination methods• General notification• Document translation• See example
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EIGHT REQUIRED ACTIONS (CONTINUED)
5. Provide additional information upon request• In response to a complaint investigation• To resolve concerns about possible non-
compliance
6. Prepare and submit a Title VI program• Report certain general information as part of
grant application
7. Analyze impact of construction projects• National Environmental Policy Act (NEPA)• Categorical exclusion• ODOT will work with system to determine in a
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EIGHT REQUIRED ACTIONS (CONTINUED)
8. Promote inclusive public participation• Conduct public outreach and involvement
activities with minority and low-income individuals
• Agency determines most appropriate approacho Should seek out and consider the viewpoints
of minority, low-income, and LEP populations when conducting public outreach and involvement activities
o Early and continuous opportunity for input• ODOT emphasized since most overlooked
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GUIDANCE FOR TRANSIT AGENCIES
Prepare demographic analysis• Maps with overlays showing distribution of service
to protected populations Set system-wide service standards
• Vehicle load, headway, assignment, access, amenities
Monitor and compare Assess impact of service and changes Document procedures for informing protected
populations of upcoming service changes
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Sample graphic from the New Hampshire DOT Title VI Overview Report
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Sample graphic from the New Hampshire DOT Title VI Overview Report
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Sample graphic from the New Hampshire DOT Title VI Overview Report
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GUIDANCE FOR TRANSIT AGENCIES (CONTINUED)
Provide a racial breakdown of non-elected boards, advisory councils, and committees• Encourage participation of protected populations’
representatives
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ENFORCEMENT Procedures for securing voluntary
compliance• Identify deficiency or non-compliance
oQuality assurance reviewoCompliant
• Notification of sub-recipientoLetter of finding
• Recipient responseoPlanned corrective actionoSufficient justification for action
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ENFORCEMENT (CONTINUED) Procedures for securing voluntary
compliance (continued)• Final decision
oODOToUSDOToDepartment of Justice
Enforcement Proceeding• Suspend or terminate Federal financial assistance
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PROVIDE MEANINGFUL ACCESS TO PERSONS WITH LIMITED ENGLISH PROFICIENCY AND LOW LITERACY
Persons with Limited English Proficiency (LEP)• Persons who do not speak English as their primary
language• Persons who have a limited ability to read, write,
speak, or understand English Households with Limited English Proficiency
(LEP)• No one over age 14 speaks English well, and is
linguistically isolated
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LEP POPULATION IN THE US
More than 10 million do not speak English at all or well
Increased by 65% from 1990 to 2000 Other common languages• Spanish• Chinese• Vietnamese• Korean
Greater than 11% of LEP persons take transit to work
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LOW LITERACY
National Literacy Council defines “low literacy” as:• “An individual’s ability to read, write, and speak
English and compute and solve problems at levels of proficiency necessary to function on the job and in society, to achieve one’s goals, and develop one’s knowledge and potential.”
On a scale of 1 – 5, 21% had the lowest literacy skills (level 1) and 27% had the second lowest (level 2)
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LEP EXECUTIVE ORDER 13166
Each Federal agency shall examine the services it provides and develop and implement a system by which LEP persons can meaningfully access those services
Required in all ODOT and FTA program applications and proposals
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DOT LEP GUIDANCE
Two methods• Agencies serving significant populations of LEP
personsoDevelop a language implementation plan
• Agencies serving small populations of LEP personso Implement procedures to reasonably provide
meaningful access
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SIGNIFICANT LEP POPULATION – DEVELOP A LANGUAGE IMPLEMENTATION PLAN
FTA publication• “Implementing the Department of
Transportation’s Policy Guidance Concerning Recipients’ Responsibilities to Limited English Proficiency (LEP) Persons: A Handbook for Public Transportation Providers.”
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FOUR FACTORS INCLUDED IN PLAN
1. Identify number or proportion of LEP persons eligible or likely to be served• Compare service area with geographic
distribution of LEP persons
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Sample graphic from the New Hampshire DOT Title VI Overview Report
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FOUR FACTORS INCLUDED IN PLAN (CONTINUED)
2. Determine frequency with which LEP persons come into contact with the service• Track number of calls or service requests made by
LEP persons• Track number of requests for a translator, travel
trainer• Track number of LEP persons that attended public
meetings or outreach activities
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FOUR FACTORS INCLUDED IN PLAN (CONTINUED)
3. Define the nature and importance of the program, activity, or service provided to LEP persons• System’s mission statement• Provide a trip purpose summary• List major trip generators
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FOUR FACTORS INCLUDED IN PLAN (CONTINUED)
4. Identify resources and costs associated with providing meaningful access to LEP persons• Identify others in community that address the
needs of LEP persons• Identify resources available in local community
oResources that can provide oral and written translation
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SMALL LEP POPULATION – IMPLEMENT REASONABLE PROCEDURES TO PROVIDE MEANINGFUL ACCESS
No written plan requirement Minimum recommendations• Summaries of vital documents should be
translated upon request• Qualified community volunteers should be
engaged to provide oral translation when needed Other actions as appropriate
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REASONABLE STEPS
Smaller agencies are encouraged to explore the most cost-effective means of delivering competent and accurate language services before limiting services due to resource concerns
Reduce cost by technological advances, reasonable business practices and sharing language assistance materials and resources
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REASONABLE STEPS – PROVIDING LANGUAGE ASSISTANCE
Oral interpretation in person• Train bilingual staff to serve as interpreters or
translators• Use qualified community volunteers to provide
interpretive services• Hire qualified interpreters for critical
presentations/meetings provided to a high volume of LEP persons
Oral interpretation via commercially available telephonic interpretation services
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REASONABLE STEPS – PROVIDING LANGUAGE ASSISTANCE (CONTINUED)
Guidance on oral interpretation services• Ensure competency of interpreters• Ensure interpretation is made in a timely manner• Utilize skills of existing staff• Contract with interpreters when there is no
regular need for a particular language skill
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REASONABLE STEPS – PROVIDING LANGUAGE ASSISTANCE (CONTINUED)
Written translation• Translate entire reports that provide essential
information• Translate a short description of the report• Translate reports upon request• Use qualified translators to make sure documents
are accurate• Translate into languages where there is identified
need (four factor analysis)• Use pictures/pictograms for low-literacy persons
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ELEMENTS OF AN EFFECTIVE IMPLEMENTATION PLAN ON LANGUAGE ASSISTANCE
Conduct needs assessment Develop language assistance measures Train staff Provide notice to LEP persons Expand outreach efforts Monitor and update plan
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ENGAGING LOW-LITERACY AND LEP POPULATIONS IN TRANSPORTATION DECISION MAKING
Hold public meeting in accessible locations and at accessible times
Provide notice through radio announcements Be observant and sensitive to people who
cannot read English Give opportunity to provide verbal comments Use maps, diagrams, pictures
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